HomeMy WebLinkAboutUnion 89-03-17IN THE MATTER OF AN ARBITRATION
BETWEEN:
CAMBRIAN COLLEGE
(The Employer)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF A UNION GRIEVANCE - #87A98
BOARD OF ARBITRATION: Kenneth P. Swan, Chairman
R.J. Gallivan, Employer Nominee
Larry Robbins, Union Nominee
APPEARANCES:
For the Employer: Wallace Kenny, Counsel R. Hurley
A. Favor
L. Bouchard
For the Union: Malcolm Ruby, Counsel
Bill Kuehnbaum, Local President
#5665 - [15]
AWARD
This arbitration involves a grievance filed on behalf
of the Local Union relating to the employment of persons in the
Tractor-Trailer Driver program. At the outset of the hearing,
the parties were agreed that the board of arbitration had been
properly appointed, and that we had jurisdiction to hear and
determine this matter.
The grievance is in the following terms:
The .College has failed to include teachers in
the Tractor-Trailer Drivers course in the
bargaining unit. This violates at least
Article 7, Appendix III 1 (d) and Appendix III
~_.
The collective agreement provisions to be considered
are as follows:
Article 1
RECOGNITION
1.01 The Union is recognized as the ex-
clusive collective bargaining agency for all
academic employees of the Colleges engaged as
teachers (including teachers of Physical
Education), counsellors and librarians, all
as more particularly set out in Appendix I
hereto save and except Chairman, Department
Heads and Directors, persons above the rank
of Chairman, Department Head or Director,
persons covered by the Memorandum of Agree-
ment with the Ontario Public Service Employ-
ees Union in the support staff bargaining
unit, and other persons excluded by the
legislation and teachers, counsellors and
librarians employed on a part-time or
sessional basis.
NOTE A: "Part-time in this context shall
include persons who teach six hours per week
or less."
NOTE B: "Sessional in this context shall
mean an appointment of not more than twelve
months duration in any twenty-four month
period."
Article 7
MANAGEMENT FUNCTIONS
7.01 It is the exclusive function of the
Colleges to:
(a) maintain order, discipline and
efficiency;
(b) hire, discharge, transfer, clas-
sify, assign, appoint, promote,
demote, lay-off, recall and suspend
or otherwise discipline employees
subject to the right to lodge a
grievance in the manner and to the
extent provided in this Agreement;
(c) to manage the College and, without
restricting the generality of the
foregoing, the right to plan,
direct and control operations,
facilities, programs, courses,
systems and procedures, direct its
personnel, determine complement,
organization, methods and the
number, location and classification
of personnel required from time to
time, the number and location of
campuses and facilities, services
to be performed, %he scheduling of
assignments and work, the exten-
sion, limitation, curtailment, or
cessation of operations and all
other rights and responsibilities
not specifically modified elsewhere
in this Agreement.
7e02 The Colleges agree that these functions
will be exercised in a manner consistent with
the provisions of this Agreement.
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Appendix III
SESSIONAL EMPLOYEES
l(d) If the college continues a full-time
position beyond one (1) full academic year of
staffing the position with sessional appoint-
ments, the college shall designate the
position as a regular full-time bargaining
unit position and shall fill the position
with a member of the bargaining unit as soon
as a person capable of performing the work is
available for hiring on this basis.
2. The College will give preference to
the designation of full-time positions as
regular continuing teaching positions rather
than sessional teaching positions subject to
such operational requirements as the quality
of the programs, enrolment patterns and
expectations, attainment of program objec-
tives, the need for special qualifications
and the market acceptability of the programs
to employers, students, and the community.
The College will not abuse the usage of
sessional appointments by combining sessional
with partial-load service and thereby
maintaining an employment relationship with
the College in order to circumvent the
completion of the minimum twelve (12) months
sessional employment in a twenty-four (24)
month period.
A person assigned to replace a full-time
regular employee for up to fourteen (14)
working days for unplanned absences in any
month shall not have such period(s) con-
sidered as sessional employment for the
purpose of the computation of the twelve (12)
months sessional employment. During such
periods such a person shall be paid as if
partial-load and within the range of partial-
load hourly rates as set out in Appendix II
hereof.
Other matters concerning the use of
sessional appointments may be referred to the
E.E.R.C. which shall deal with these matters
as priority items.
In addition, the Union referred in argument to the
following provisions of the Colleges Collective Bargaining Act,
R.S.O. 1980, c. 74:
1. (b) "bargaining unit" means the
academic staff bargaining unit of employees
or the support staff bargaining unit of
employees set out in Schedules 1 and 2;
(f) "employee" means a person employed
by a board of governors of a college of
applied arts and technology in a position or
classification that is within the academic
staff bargaining unit or the support staff
bargaining unit set out in Schedules 1 and 2;
48.--{2) Where a conflict appears between
any provision of an agreement and any
provision of any legislation, the provision
of the legislation prevails·
52. Every agreement shall be deemed to
provide that the employee organization that
is a party thereto is recognized as the
exclusive bargaining agent for the bargaining
unit to which the agreement applies.
67.--(1) The bargaining units set out in the
Schedules are the units for collective
bargaining purposes under this Act.
(2) The employee organization that is
party to the agreement covering the academic
staff bargaining unit or the support staff
bargaining unit on the 18th day of July 1975
shall be deemed to have been granted bargain-
ing rights in relation to such bargaining
unit on the 18th day of July, 1975.
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SCHEDULE 1
The academic staff bargaining unit
includes the employees of all boards of
governors of colleges of applied arts and
technology who are employed as teachers,
counsellors or librarians but does not
include,
(viii) teachers, counsellors or librarians
who are appointed, for one or more sessions
and who are employed for not more than twelve
months in any twenty-four month period.
The facts on which this matter is to be decided are not
really in dispute. The College offers a course entitled
"Tractor-Trailer Driver", of four weeks duration, as one of its
adult training programs. The course is listed and described in
the College Calendar, students apply to the College for admis-
sion, and they report for training to a location on the College
parking lot near the Trades Building. A College certificate is
awarded but the real purpose of the course is to examine for the
Ministry of Transportation and Communications Class "A" licence,
and the actual course content is specified by that Ministry.
It appears that the Ministry first introduced a
requirement for Class A licences for tractor-trailer drivers in
1977; previously only a valid Chauffeur's Licence was required to
operate such vehicles. Shortly after, the College began its
course, and retained the services on contract of a driving
school, Aaron Driving School, which had been in existence since
1973, engaged in private instruction and also in driver education
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courses operated under contract with local high schools. The
course has been taught by Aaron Driving School ever since that
time.
Aaron Driving School is owned by Mr. Stephen Farrell.
He does most of the instruction for students, including all of
the classroom instruction. He is assisted during the road
driving phase of training, the last tw~ weeks of each course, by
another instructor, while his wife handles administration for the
school. There are no other persons involved in either Aaron
Driving School or the instruction program at the College.
Originally, Aaron Driving School had other contracts
with Northern College, government departments and other clients.
By 1979 its contracts with Cambrian College had virtually taken
over all of its time, and at the time of the grievance Cambrian
College was the school's only instruction contract.
Mr. Farrell has been certified by the Ministry of
Transportation and Communications as an instructor and examiner
for Class A licences. At the end of the course, therefore, he
administers a Ministry examination to each student, upon the
successful completion of which the Ministry issues a Class A
driving licence.
It appears that there are two tractor-trailer trucks
involved in the training program, both of which are owned by
Cambrian College. Mr. Farrell does the routine and minor
maintenance on these vehicles, but major repairs and all opera-
ting, expenses are paid by the College. The vehicles are parked
in the College parking lot, but Mr. Farrell has no office in the
adjacent Trades Building. There is a message box in an office
there which students and the College a~m~nistration use to
contact him, and he is apparently allowed ~ use telephones in
certain locations as well. Otherwise, he m~rks out of a jeep,
which is the only vehicle owned by Aaron Driving School. All
books and materials for the course which are not supplied by the
Ministry are provided by the College, an~ the College also
provides all necessary audio-visual and radio transmission
equipment for the course.
There is a written contract between the College and
Aaron Driving School which dates from 1977, with amendments only
to the amount to be paid to the school for each student
instructed. While the contract specifies the length of the
course and the breakdown between classroom and practical train-
ing, it provides no detailed curriculum, nor mny special require-
ments relating to instruction. There are, .h~ever, a substantial
number of conditions relating to administration. Mr. Farrell's
evidence was that all course requirements, even the breakdown
between classroom and practical instruction, come from the
Ministry of Transportation and Communications.
While one might express surprise at the length of time
which this course has been offered without complaint by the
Union, the evidence of Mr. Bill Kuehnbaum, President of the Local
Union, is that he only became aware of the matter when a member
of his executive was transferred to the Trades Building and
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noticed in some detail how the course was being offered, and in
particular the fact that it was not being offered by teachers who
were College employees. There had apparently been some concern
during a strike in the autumn of 1984, when the trucks were
observed crossing the picket lines. It seems that only later,
however, was the Union's attention turned to the precise nature
of the arrangements made for this course, as opposed merely to
the existence of the vehicles with the College's name on them,
and their operation in and around the College premi~e~.
Based on these facts, three issues arise. The first is
whether the Employer is entitled, under the terms of the collec-
tive agreement and the statute, to contract out work which
constitutes teaching on a course operated by the College. The
second point is whether, by its long inaction in respect of this
course, the Union is estopped from complaining about this
arrangement at the present time. The final issue is whether,
even assuming that the College has the right to contract out
work, the present arrangements constitute a valid contracting
out, or whether the instructors employed by Aaron Driving School
are, in fact and in law, really employees of the College entitled
to the benefits of the collective agreement.
Neither party urged us to depart from the general
principle of arbitral jurisprudence to the effect that, absent
express language in the collective agreement to the ~.Dntrary, a
bona fide contracting out of work to non-employees who are not
within the bargaining unit is a management right: see Re United
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Steelworkers of America and Russelsteel Ltd., (1966) 17 L.A.C.
253 (Arthurs), Re Kennedy Lodge Nursing Home and Service Employ-
ees' Union, Local 204, (1980) 28 L.A.C. (2d) 388 (Brunner), Re
401548 ontario Ltd. and Retail, ~holesale and Department Store
Union, Local 448 (1980) 111 D.L.R. (3d) 502, 28 O.R. (2d) 697
(Ont. Div. Ct.). It was common ground between the parties that
the collective agreement does not specifically prohibit contract-
ing out of work of the kind here at issue. The Union argues,
however, that the effect of the Colleges Collective Bargaining
Act, and in particular the sections set out above, do prohibit
contracting out.
The College, however, argues that the effect of
Schedule 1 of the Act is simply to specify the definition of the
bargaining unit in much the same way as the unit might be defined
by a labour relations tribunal under other legislation, and that
the rest of the legislation simply makes arrangements for
collective bargaining in relation to that bargaining unit. In
the College's submission, the critical question is whether a
particular person is one of "the employees of all boards of
governors of colleges of applied arts and technology who are
employed as teachers". The College's position is that Mr.
Farrell and his fellow instructor are not "employees" and are not
"employed as teachers" by the board of governors of this College,
and that they therefore do not fit within this bargaining unit,
although they undoubtedly would if they were employees.
We find this reasoning persuasive. The essence of a
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true contracting out is to give work which might be performed by
a bargaining unit member to the employee of another entity. Once
someone is an employee of another entity than the board of
governors of the College, that person does not fit within the
definition of the academic staff bargaining unit as specified in
Schedule 1 to the Act, and the Act therefore does not apply to
that person. In our view, the most important matter to be
considered is not the provisions of the Act, but whether the
College has validly contracted this work to Aaron Driving School,
so as to remove the employees of Aaron Driving School from the
definition of the statutory bargaining unit.
As to the issue of estoppel, we have only the evidence
of Mr. Kuehnbaum to consider. While it might be somewhat
surprising that driver training activity could continue on a
monthly cycle for years without the Union's attention ever being
attracted to it, Mr. Keuhnbaum explains that short term courses
are very hard for the Union to monitor, and that no College
document, such as a report on persons hired as sessional lec-
turers, was ever provided to attract the Union's attention to
this particular course. In the circumstances, we accept Mr.
Keuhnbaum's evidence, and find that the Union's silence on this
matter was due to a lack of knowledge, rather than any ac-
quiesence in the College's practice. In any case, it is dif-
ficult to see why, even if there existed an estoppel here, that
estoppel could not be put to an end by notice to the Employer,
which notice could well be provided by the filing of this
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grievance. Any detrimental reliance which might operate would
operate in relation to courses offered in the past, and could
therefore be accommodated by the calculation of damages. By
whatever reasoning, therefore, we find that the Union is not
estopped from bringing the present grievance on to arbitration at
this time.
The final matter to be considered, therefore, will be
determinative of all of the issues in this case; is the
Employer's practice in having the Tractor~Trailer Driver course
taught by Aaron Driving School a valid contracting out of work
which could clearly be performed by members of the bargaining
~nit or is it merely a sham disguising the hiring of Mr. Farrell,
and perhaps others, contrary to the collective agreement, as
employees working entirely within the bargaining unit's function?
The parties were unable to refer us to any cases
arising under this collective agreement or its predecessors on
this issue. Instead, we were referred to Re Ford Motor Company
of Canada Ltd. and United Plant Guard Workers, Local 1958, (1981)
1 L.A.C. (3d) 141 (MacDowell) and Re Maple Leaf Mills Ltd., Grain
Elevator Division and Brotherhood of Railway, Airline and
Steamship Clerks, (1986) 24 L.A.C. (3d) 16 (Devlin). The
Employer relied on the first of these cases, while the Union
relied on the second.
Before turning to a discussion of these cases, and to
our conclusions in this matter, we think that it does not really
matter that work was not here "contracted out" in the strict
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sense, since the work was never in fact performed other than as
it is at the present time. When this course began to be taught,
and at all times since, it was taught through Aaron Driving
School by Mr. Farrell. On the other hand, another course, which
is offered by the College and is taught by an employee covered by
the collective agreement is entitled "School Bus Driver Training
Course". There seems to be no doubt that, upon a comparison of
the two course descriptions, these courses are so similar as to
indicate that the College could easily have decided to teach the
Tractor-Trailer Driver course through an employee rather than
through a contractor. In our view, therefore, the same con-
siderations ought to be applied as would be had the College taken
work previously performed within the bargaining unit and given it
to an outside contractor instead.
There is, as will be seen from the facts set out above,
no doubt that the relationship between Aaron Driving School and
the College is in form a contract for services, rather than
employment.. But form is never conclusive of these matters.
Rather, a number of tests have been devised to assist the courts,
and arbitrators, in determining what, in substance, is the
relationship between the alleged contractor and the alleged
employer. A useful review of the jurisprudence is found in the
Re Maple Leaf Mills case, at pp. 25-29:
In considering the criteria which have
been developed to differentiate between an
employee and an independent contractor, it is
appropriate to begin with the decision of the
Privy Council in Montreal v. Montreal
- 13 -
Locomotive Works Ltd. et al., [1974] 1 D.L.R.
161, [1946] 3 W.W.R. 748. There Lord Wright
enunciated the well-known fourfold test to
the following effect [p. 169]:
In earlier cases a single test,
such as the presence or absence of
control, was often relied on to
determine whether the case was one
of master and servant, mostly in
order to decide issues of tortious
liability on the part of the master
or superior. In the more complex
conditions of modern industry, more
complicated tests have often to be
applied. It has been suggested
that a fourfold test would in some
cases be more appropriate, a
complex involving (1) control; (2)
ownership of tools; (3) chance of
profit; (4) risk of loss. Control
in itself is not always conclusive
.In many cases the question can
-- .
Only be settled by examining the
whole of the various elements which
constitute the relationship between
the parties.
The fourfold test has been adopted by a
number of boards of arbitration in determin-
ing whether the employer has effected a
genuine contracting out: Re U.A.W., Local
1566 and Wean-McKay of Canada Ltd. (1971), 23
L.A.C. 27 (Palmer); Re C.U.P.E., Local 1 and
Toronto Rydro-Electric System (1972) ,
summarized 24 L.A.C. 308']Palmer), and
Amplitrol Electronics Ltd. and Communication
workers of America, supra. The test,
however, is not to be applied mechanically
and the significance of the factors "must
inevitably be established in relation to the
circumstances of each case"; United Brother-
hood of Carpenters & Joiners'of America,
Local 1747 v. Baron Dry Wall Ltd., 65
C.L.L.C. para. 16,029 (Ont. L.R.B.); Re
U.A.W., Local 1566 and Wean-McKay of Cana~
Ltd., supra, and Re Canadian Industries Ltd.
and Int'l Union of District 50, Region 75,
United Mine Workers of America, Local 13328
(January 3, 1972), unreported (Schiff);
upheld in Re Canadian Industries Ltd. and
Int'l Union of District 50, Allied & Techni-
- 14 -
cal Workers of United States & Canada, Local
13328 (1972) , 27 D.L.R. (3d) 387, [1972] 3
O.R. 63, 72 C.L.L.C. para. 14,130 (Ont.
C.A.); leave to appeal refused 29 D.L.R. (3d)
640n, [1972] S.C.R. ix.
In this case, it is not a question of
whether the security guards assigned to the
company premises subsequent to January 1,
1985, are themselves independent contractors.
There is no dispute that these individuals
are employees and the issue is whether they
are employees of the company. In such
circumstances, the factors of chance of
profit and risk of loss have not been
considered particularly meaningful and boards
of arbitration have focused predominantly on
the factor of control, with some considera-
tion being given to ownership of tools: Re
Norton Co. of Canada, Ltd., Hamilton an-~
U.S.W, C.I.O, Local 3696, supra, and Re Edd~
Match Co. Ltd. and United Brotherhood of
Carpenters & Joiners of America, Local 3175
(January 11, 1985), unreported (Kates).
In addressing the factor of control and
the considerations appropriate to this
factor, the board in Re Norton Co. of Canada
Ltd., Hamilton and U.S.W., C.I.O., Local
3696, commented as follows [at pp. 1454-5]:
In determining whether the
contract amounted to one for
services, as distinct from a
contract of service, some assis-
tance can be derived from the Law
of Master and Servant. It is
stated in Diamond's "The Law of
Master and Servant", Second
Edition, at Page 1, that
"The relation of master and
servant exists between two persons
where by Agreement between them,
express or implied, the one is
under the control of the other.
A person is under the control of
another as he is bound to obey the
orders of that other not only as to
the work which he shall execute,
but also as to the details of the
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work and the manner of its ex-
ecution."
At Page 5 is is stated that
"The question of whether a
person is under the control of
another is a question of fact.
Control may exist between two
persons although the one
(1) did not appoint the other;
(2) does not pay the remuneration;
(3) has no power to dismiss; and
(4) has not the exclusive control."
Similarly, in Amplitrol Electronics Ltd. and
Communication Workers of America, supra, the
board stated that the control test involves a
consideration of "the distinction between
instructions about what work is to be done
and instructions about the manner in which
the work must be performed". In Re Board of
Governors of Riverdale Hospital and C.U.P.E.,
Local 79 (1974), ~ L.A.C. (2d) 40 (Schiff),
the board noted the following [at p. 42]:
To weigh the significance of
control arbitrators have assessed
the degree of the party-employer's
right to direct the person's job
performance appropriate to the
nature of the particular job and
the person's skill. In many
awards, the party-employer did not
choose the person, did not pay him
directly and did not purport to
discipline him on the spot.
Nevertheless, arbitrators defined
the person as an employee if he
performed the job with the party-
employer's materials on the party-
employer's premises with the party-
employer exercising to a substan-
tial degree the right to direct the
job performance.
In Mayer v. J. Conrad Lavi~ne Ltd.
(1979), 27 O.R. (2d) 129, the Ontario Court
of Appeal suggested that the fourfold test
has now been enlarged by the "organization
test" as the appropriate means of differen-
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tia%ing between an employee and an indepen-
dent contractor. Referring to the fourfold
test enunciated in Montreal v. Montreal
Locomotive Works Ltd. et al., supra, Mr.
Justice MacKinnon stated as follows [at pp.
737-8]
This test has been enlarged by the
more recent "organization test"
which was approved and applied by
Spence, J., in Co-operators Inc.
Assn'n v. Kearney (1964), 48 D.L.R.
(2d) 1. In that case (pp. 22-3),
he quoted with approval the
following passage from Fleming, The
Law of Torts, 2nd ed. (1961), at
pp. 328-9:
"'Under the pressure of novel
situations, the courts have become
increasingly aware of the strain on
the traditional formulation [of the
control test], and most recent
cases display a discernible
tendency to replace it by something
like an "organization" test. Was
the alleged servant part of his
employer's organization? Was his
work subject to co-ordinational
control as to "where" and "when"
rather than the "how"? [citing
Lord Denning in Stevenson, Jordan &
Rarrison Ltd. v. Macdonald, [1952]
! T.L.R. 101,111.]'"
Lord Denning in Stevenson Jordon &
Rarrison, Ltd. v. MacDonald et al.,
[1952] ! T.L.R. 101, referred to by
Fleming, said this:
"'One feature which seems to
run through the instances is that,
under a contract of service, a man
is employed as part of the busi-
ness, and his work is done as an
integral part of the business;
whereas, under a contract for
services, his work, although done
for the business, is not integrated
into it but is only accessory to
it.'"
As can be seen, one component of the
organization test is the traditional formula-
tion of the control test. The organization
test, however, also involves a consideration
of the role played in the party-employer's
organization by the individual whose status
is an issue.
In addition to the fourfold and or-
ganization tests, in determining the exis-
tence of an employment relationship, at least
one arbitrator has considered the criteria
developed by the Ontario Labour Relations
Board to determine which of two or more
entities is the employer for the purposes of
the Labour Relations Act: Re Ford Motor Co.
of Canada Ltd. and United Plant Guard
workers, Local 1958 (1981), 1 L.A.C. (3d) 141
(MacDowell). These factors were set out in
York Condominium Corp., [1977] O.L.R.B. Rep.
645, to the following effect:
(1) The party exercising direction and
control over the employees perform-
ing the work.
(2) The party bearing the burden of
remuneration.
(3) The party imposing discipline.
(4) The party hiring employees.
(5) The party with the authority to
dismiss the employees.
(6) The party which is perceived to be
the employer by the employees.
(7) The existence of an intention to
create the relationship of
employer-employee.
The application of these factors to a
determination similar to the one before me,
however, was doubted by the board in Re Royal
Ontario Museum and Service Employees Union,
Local 204 (1984), 16 L.A.C. (3d) 1 (Adams).
There the board suggested [at p. 32] that:
"the approach of a labour relations board
dealing with certification matters cannot be
so easily integrated into arbitral jurispru-
dence without qualification as the Ford Motor
Co. case appears to do". While the Labour
Relations Board is faced with a question
relating to the existence of an employment
relationship, the question is being asked for
a .different purpose and the criteria
developed by the board must be viewed in that
light.
Counsel for the company, in this case,
also made reference to the decision of the
board in Re Social Planning Council of
Metropolitan Toronto and C.U.P.E., Local 1777
(1980), 28 L.A.C. (2d) 134 (Knopf). There
the board specified the following criteria to
be the most important in determining whether
certain project employee~ were actually
employees of the party-employer [p. 150]:
(1) ContrOl over the selection of
employees.
(2) Control over the method and
performance of the work.
(3) Control over the decision whether
money should be paid for wages or
other expenditures.
(4) Control over the length and
duration of the performance of job
functions.
(5) Whether the work performed was part
of or integral to that of the
alleged employer.
(6) Who benefited from the work
performed.
As is apparent, a number of the factors
enunciated by the board pertain to the nature
of the control exercised by the party-
employer and by considering whether the work
was integral to the business of the party-
employer, it may also be said that the board
applied the organization test referred to
previously. In my view, the board in the
Social Planning Council award was not
endeavouring to establish a new or different
test to be applied in determining the
existence of an employment relationship, but
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was merely formulating those factors of
particular significance to its decision
"given the unique situation of the staff
selected under Government-funded projects.
'The present situation, of course, is not precisely the
same as of the cases discussed. Mr. Farrell only "works" for
Aaron Driving School in the very loosest sense; it would be far
more accurate to describe him as actually being Aaron Driving
School. It is true that he assigns some of the work under the
contract to his assistant instructor, and some to his wife, but
he is the primary instructor, and his position is solidified by
the fact that he has an examiner's certificate and can provide
the Class A licence that the course description promises by
certifying to the Ministry of Transportation and Communication
that the students have passed the appropriate tests. Our inquiry
can therefore reasonably focus on Mr. Farrell's relationship to
the College, rather than on the essential fiction that Aaron
Driving School is somehow interposed in that relationship.
A useful starting place is the issue of "ownership of
the tools", which in more modern language leads us to look at the
capital investment involved in the work to be performed. Mr.
Farrell does not own the vehicles on which instruction is given,
nor does he even maintain them at his expense. Both the initial
capital cost, and ongoing capital expenses, therefore, are borne
by the College. The College also provides all books, supplies
and materials needed, from audio-visual equipment to teach the
classroom portion of the course, to the fuel required to run the
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vehicles during the practical part of the course. While Mr.
Farrell owns a jeep which he referred to as his "office", this
appears to be more for his own convenience rather than any
requirement of the contract with the College. As far as this
test is concerned, therefore, the evidence is substantially in
favour of a finding that Mr. Farrell is an employee.
We turn next to the chance of profit and the risk of
loss, which might more reasonably be referred to as the presence
or absence of an entrepreneurial element. This is particularly
important in the present case, although it was not in the R__e
Maple Leaf Mills case, since there is no real business entity
interposed, between the person who does the work and the College,
to remove the entrepreneurial connection. Mr. Farrell really
cannot be said to be in an entrepreneurial position. As we have
already observed, he has no capital at risk. While he takes some
steps to generate demand for his course, the students are really
supplied to him by the College. While he is not paid a salary,
he is paid essentially on a "piecework" basis, at a fixed amount
per student enrolled in the course. Ne has literally no control
over the number of students who are enrolled. If the College is
unable to create enough demand, and the number of students
enrolled falls below four per truck, Mr. Farrell will be paid
less money. It would appear from his evidence that if the
numbers fall much below four per truck, the course is simply not
offered, and he is paid nothing at all. At the same time, the
maximum amount he can earn is also fixed by the number of
- 21 -
vehicles available, and as has already been observed the College
provides those vehicles. It is of some interest that, sometime
prior to the grievance, one of the College's three vehicles
became unroadworthy, and was no longer used for instruction. At
that time, the per student rate was renegotiated to, in effect,
maintain Mr. Farrell's earning level.
While he pays some expenses out of the amounts paid by
the College, the only major expense is the pay to his second
instructor. But that amount is also fixed by whether the course
is offered or not and by the maximum number of students placed on
the course by the availability of trucks for driver training.
Finally, we turn to the question of control. There is
no doubt that Mr. Farrell carries out his instruction duties
essentially without any direct supervision by the College
authorities. This probably does not differ very much from the
way in which every teacher in the College carries out his or her
duties. Moreover, the College has clearly reserved the right to
reimpose control at any time, and the contract specifically
requires Aaron Driving School to "abide by the College regula-
tions pertaining to course offerings in the Industrial Training
and Apprenticeship Department", and to operate "in accordance
with the integrity of the College in its high standards of
training". The College has reserved the right to cancel the
contract by providing written notice two weeks in advance of any
course, and no doubt would take steps to terminate the contract
otherwise if it had any significant concerns about infringement
- 22 -
of the College regulations or departures from its integrity or
its high standards of training, both of which would be express
breaches of the contract.
In fact, a significant degree of control is exercised
by the Ministry of Transportation and Communications. Mr.
Farrell testified that its inspectors monitor his course usually
twice a year, and this may well account for the fact that the
College has not found it necessary to take any more significant
steps to exercise the degree of control which the contract
undoubtedly gives it.
If we pursue instead the modern manifestation of the
control test, called the "organization test" in Mayer v. J.
Conrad Lavigne Ltd., referred to in the Maple Leaf Mills case
above, this factor points even more strongly to a finding of
employment. There is, throughout the contract, evidence of
"coordinational control" as to "where" and "when" rather than of
"how" referred to in that test. Indeed, the contract goes so far
as to specify a number of regular reports which are required both
on the outcome of the training and of Mr. Farrell's role in the
placement of graduates, and on the status of the two vehicles
used in training.
As to the other facet of the organization test, it is
clear that Mr. Farrell fits directly into the College's organiza-
tion. The work which he performs is not substantially different
from the work performed by all members of this bargaining unit,
and the evidence discloses that a course essentially similar to
this course, the School Bus Driver course, is in fact taught by
an employee of the College.
None of the other tests developed in the various cases
referred to in Re Maple Leaf Mills, most of which apply to a
situation where there exists another business entity which has
done the actual contracting, the status of whose alleged
employees is to be considered, are really applicable to the
matter before us. What we do find, on a review of all of the
criteria which are applicable, is that every single one points,
more or less strongly, to a finding that Mr. Farrell is an
employee of the College rather than a true independent contrac-
tor. On the basis of these findings, the only conclusion we can
reach is that the grievance must be allowed, and that Mr.
Farrell, at least, must be declared to be an employee of the
College, and therefore covered by the collective agreement.
The result of this determination, the College informed
us, is that it likely would not be able to justify offering
further instruction in this course. The contribution margin
analysis which it provided to demonstrate this does not, however,
clearly show that this would be a necessary outcome of any such
finding. It was also argued that, because of the requirement for
direct contact with the students by Mr. Farrell, because of his
certified instructor status from the Ministry of Transportation
and Communications, offering the course as outlined by that
Ministry would require Mr. Farrell to have contact-hour exposure
far beyond what is permitted in the collective agreement. The
- 24 -
Union responds by saying that the collective agreement permits
alternative workload arrangements, and that those could be made
to resolve this matter.
In our view, these considerations are really irrelevant
to our task, which is to interpret the collective agreement.
While arbitrators are careful not to assign to a collective
agreement a meaning which would render it an absurdity, there is
nothing to show that the outcome here would be absurd. In fact,
it ia of some significance that the College is able to offer
another driving course, the School Bus Driver course, entirely
within the strictures of the collective agreement. Whether it is
as profitable, as convenient or as satisfactory to do so is not
· really relevant.
On the other hand, it is clear that the relationship
between Aaron Driving School and the College is one of long
standing, and a number of people have come to rely upon the
arrangement, including Mr. Farrell and his staff. There are also
undoubtedly a number of students who are waiting for an oppor-
tunity to take a course for which they have already applied. As
a result, for the moment we limit ourselves to a declaration that
Mr. Farrell is, within the meaning of the collective agreement,
an employee who is a part of the bargaining unit. We remit the
matter of how this declaration should be implemented in practice
to the parties, with the strong recommendation that any implemen-
tation take account of the long standing nature of Mr. Farrell's
relationship with the College, and of the expectations of Mr.
- 25 -
Farrell, his other employees, and the students.
We will, of course, remain seized of the grievance
should there be any difficulty in implementing our decision.
DATED AT TORONTO, Ontario this 17th day of March, 1989.
Ke~n, Chairman
I dissent; see attached "R.J. Gallivan"
R.J. Gallivan, Employer Nominee
I concur "Larry Robbins"
Larry Robbins, Union Nominee
DECISION OF R. J. G~LLIYAN
There is in evidence before us 'a cony of the contract
between Cambrian College and A. Aaron Driving School. It an.~ears on
its face to be a normal commercial contract setting ou~ the nrice the
College will oa.v to A. Aaron Driving School for or6viding instruction
in tractor-trailer driving to certain adult trainin~ students of the
Colle.=e. The contract sets out the agreement of both oarties to nro-
mote the course nublicly and to seek students for it, sets the number
of hours of tnstruction Aaron must Eive to each student, the
ne time over v~hich this instruction is to be given, ~'~aron's resoonsib-
ilit.v for revortin~ to the College on the orogress and eventual
olacenent of each student, an~t ~aron's resoonsibilit~ for the general
maintenance, safety and sunervision of the tractor-trailers owned
the College. '~he contract ma.v be terminated by mutual agreement at
an.v time or uoon two weeks written notice by either oarty. It
be noted that the contract does not s.oecify who among Aaron's
e~lo.vees is to ~o the training, how many trainers Aaron is to employ,
who it shall employ nor their qualifications. Those matters are for
decision exclusively by Aaron. The contract simply sets a ~rice the
College will Day ~aron for each student.
The history and Dractical a~nlication of that contract
was ex~.lained in evidence by Steohen Farrell, owner of the A. Aaron
driving school. His evidence was that his driving school business has
been in existence since 1973 offering driver training, that it first
contracted., with the College in 1976 to provide tractor-trailer driver
training, that for several years thereafter it continued to have a
number of different clients in addition to the College, that at the
time of the grievance the College was its only training client, and
that Aaron did not judge itself in any way restricted by its contract
with the College from offering driver training to any other client
if it so wished..His comoany is free to hire as many emoloyees as it
decides are necessary to service as many customers as it cares to
solicit. That it has chosen in recent years to limit itself to a
contract with the College is a free commercial choice of Aaron's owner
Farrel! and not a requirement or consequence of the terms of .baron's
contract with the College. At the time of our hearing this grievmnce
in October 1987, Aaron'orovided en~lo~ent for' its owner, the owner's
wife and one other instructor. There is no obligation under the
contract betw'een Aaron and the College that Farrell himself act as an
instructor. In fact the evidence was that several years ago while
he v~as ill one of his emoloyees reolace¢~ Farrell for an extended
~eriod of time. However, it seems likely that because of Ministry'
of Transportation regulations (which will be discussed later) Aaron's
usefullness to the College would be limited if someone in ~aron's
e~lo~ was not licence~ by that Ministry.
Given the foregoing, I must dissociate m~;self from
the decision of mY colleagues essentially to dismiss those facts
which were uncontradicted in evidence before us, and register mM
disagreement with their conclusion that the contract between Aaron
an~ the College is all just a fiction designed to ~ask Farrell's
relationship with the College. In a dispute over subcontracting,
those facts are highl~ significant and cannot be dismissed or given
so little weight as virtually to be ignored.
I do however a~ree with the ma~rit~ that under this
collective a~reement there is no restriction on the College
manmEement's right to subcontract bargaining unit work, nor is
there any such restriction in the Colleges Collective Bar~ainin~ Act.
That being the case, the fact that Aaron's emoloyees oerforn work
for the College similar to other courses taught by emoloyees within
the bargaining unit (such as School Bus Driver training) is
irrelevant. The College is free to have such work done by its own
emoloyees or to contract it out. In other words, the College is
entitled by its ~anagement rights to hire emoloyees to do the work
it wants done, or (subject only to labour law desi.~ned to orevent
circumvention of certain union rights) to have its available work
~one for it by indenendent contractors. If it decides on the for~er,
the emoloyees it hires are then subject to the confines of the
barMaining unit and to the strictures of the collective agreement;
if the latter, the contractor deals indeoendently with the College
in co~oetition with others ~vho ma)~ tender for the sa~e work. The
auestion before us then simoly becomes whether as a consequence of
the contract between Aaron and the College, and the manner of its
aoolication, Farrell and the other employees of Aaron are indeoend-
ent contractors.
A number of tests have been develooed by the courts,
labour relations tribunals and arbitration boards for heloing to
answer such a auestion.' While these tests have been refined and
apolied in various ways over the years deoending uoon what alleged
violation is being weighed in a oarticular case, the fourfold, test
ouoted by the majority for determining a contractor's status
generslly has been found adequate for the tyoe of case before us.
Notwithstanding the various additions or refinements made to these
tests, it is noteworthy that the greatest weight and oriority
continues regularly to be given by the courts, labour relations
and arbitration boards to the issue of "control". See for exanole
re: N~n~real v. ~ontreal Locomotive Works Ltd. et al., (1974) 1
D.L.R. 161 (P.C.); re: OPSUE v. the Crown in the Right of Ontario
(~.Tinistr?T of the Attorney General) decision of P. C. Picher, Ontario
Public Service Labour Relations Tribunal, Jan. 1988, unreoorted; and
nunerous arbitration board awards such as re: De Havilland Aircraft
of Canada Ltd. and United Automobile ?.'orkers, Local 112, 9 L.A.C.(3d)
where after a review of the jurisorudence the arbitrator says at o.377:
"It is clear that of all the tests
· - enunciated, the question of control
is pre-eminent."
From the evidence before us it is clear that the
College exercizes almost no control over .~aron or its employees. It
does not set Farrell's or his emoloyees' working hours. It does not
establish the course content nor fix when or how the course is to be
given. It does-not decide who or how many emolo~ees Aaron sh~ll
e~o!oy. It does not even require that Farrell be one of the instructors.
He is free to teach hinself or to have others do it for him so lon~
as ~iinistry of Transoortation, not College, requirements are met. The
College ~:oes not evaluate the job oerform..~ance of individual instructors
or others in Aaron's employ nor train them nor discinline them nor
set their wage rates. Those are Aaron's manage~ent's resoonsibi!it?.
The College's contract with Aaron does not limit the latter's ri
to have other customers concurrently with the College.
The tractor-trailer course content is set by the
7.~inistry of Transportation, not the College. That Ministry establishes
the minimum number of hours of training to be given an.~'~ it is
insnectors from that Ministry, not the College, who monitor Aaron's
work an.~ students' orogress. It is Aaron on behalf of the .~.:inistry,
not the College, who determines a ootential stu~ent's suitability
to enter the course. It is the ?'~.inistrM, not the College, which sets
the standards to qualify for a licence uoon graduation. .Thus the
ma~or control over Aaron and its employees is by the Minister of
Transnortation, not the College. To hole], that desoite such a degree
of control by a third oartw (the [.]inistry) it is really the College
which is exercizing control to such an extent as to make Aaron a
~.eoendent contractor and thus an emoloMee of the College (which as
I have demonstrated has no control over essential elements of Aaron's
work) is to misaooly the control test.
The fact that the contract between Aaron and the
College requires Aaron to "abide by the College regulations" is not
indicative of control, contrary to what my colleagues hold for, as
was found in re: Federated Building ~Vaintenance Comnany Limited
(l~gS) OLRB Nov. 1585 at page 1595:
"A degree of functional interdeoendence
is inevitable, and implicit in many
subcontractinE arrangements."
I conclude therefore, that on the key test of "control"
the evidence points strongly to a conclusion that Aaron and its
emnloyees are indenendent contractors, not emoloyees of the College.
Unlike my colleagues.I am unable to conclude that because the
College can, upon notice, terminate its contra~t with Aaron it
thereby has sufficient '"control" to make Aaron's emnloyees servants
of the College. If that were the criterion, the emnloyees of any
business fro~ which the College buys service under a terminable
contract could arguably be College employees, and no subcontractinE
of bargaining unit work by a unionized emoloyer even though oermitted
by law and contract, as here, could ever be valid.
That the College owns the tractor-trailers used by
Aaron is not oersuasive in this case just as it has not been in the
extensive jurisorudence where contract cleaners or food service
workers, for examole, obviously oerform their work on the emoloyer's
equioment and oremises. Clearly the College's trucks are the major
caoital investment reauired for the course, but not the only
equipment. Aaron and its employees do not have an office at the
ColleMe. Aaron's office is in Farrell's home and his business ohone,
listed in directories under Aaron's name, is in that office. The
~.!inistry of Transoortation, not the College, suoolies equipment used
by Aaron for eye testing of students, and Aaron owns the tools used
to do regular routine maintenance and reoair of the College's
trucks. Those tools are transoorted in a vehicle owned by Aaron, the
cost of which is born by Aaron from the fees received from the
Co!leEe.
Finally, as already outlined, it is Aaron which
~ecides whether or not to run a oarticular session of the course.
If, in .~aron's judgement, there are insufficient students to make
it economically viable to conduct a session, Aaron is free to seek
a~itional student recruits or simply not to schedule the course.
The scheduling decision is Aaron's which has the right, regularly
exerdzed, to decide not to run a session if there are too few
students. Aaron thus accents the major burden of the risk of loss
or the oooortunity for orofit. Since Aaron is oaid a fixed fee net
student, it risks not workin~ yet having to carry its ongoing
fixe~ costs if a session is cancelled for want of students ~
loss is to .~aron not the College which, through its contract
~.'~ith Aaron essentially has shifted the risk from itself to another
emolover. As with the "control" test, the test of who bears the risk
of loss or chance for orofit noints strongly to Aaron and its
e~lo?ees as being indeoendent .contractors.
Thus the oreoonderence of evidence suooorts a
conclusion that the contract between the College and A. Aaron
DrivinK School is a valid contract for service with an indeoendent
contractor, and I so find. Neither the collective agreement nor the
Colleges Collective Bargaining Act orevents the College fron
exercizing its right to subcontract work to non-emoloyees who, if
instead were emoloyed directly by the College, would normally fall
within the bargaining unit. The College has exercized that right
in this case and accordingly there has been no violation of the
collective agreement. The A. Aaron Driving School and its e~oloyees
are indeoendent contractors and not emoloyees of the College.