HomeMy WebLinkAboutWigle 90-10-09 THE MATTER OF AH ARBITRATION
BETWEEN: FANSHAWE COLLEGE
The Employer Caat A
and
90B375
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
The Union
Local 110
AND IN THE HATTER OF the grievance of Kat_~rYn~ig~le (OPSEU File No. 90B375)
alleging incorrect calculation of seniorx~.
Board of Arbitration: D.D. Carter, Chair
W.A. Correll, Employee Nominee
J. McManus, Union Nominee
Appearances for the Union: M.A. Kuntz, Grievance Officer
K. #igle, Grievor
T. Geldard, Local ilO
G. Ford¥ce, Local
Appearances for the Employer: B. Brown, Counsel
J. Mills, Fanshawe College
hearing of this matter was held at London on September 7, 1990.
AWARD
AWARD
The grievor, Kathryn Wigle, commenced euployment as a teacher in the Human
Services Division of Fanshawe College on August 31, 1987. After the connencement
of her employment and, while still a probationary employee, she applied for and
was granted a leave of absence because of pregnancy. This leave covered the
period ~arch 3, 1989 to June 30, 1989 and, after the normal summer vacation
period, she resumed her active teaching duties. In early January of 1990 she was
advised that as of December 31, 1989, she would be classified as "regular", which
!
meant that she had successfully completed her probationary period.
The difference underlying this grievance arises from the fact that the
grievor was given no seniority credit for the period of her pregnancy leave. It
is the union's position that in determining whether seniority accrues during
pregnancy leave no distinction should be drawn between probationary esployees
and regular, employees, as in each case seniority credit should be given for the
period of pregnancy leave. The employer, on the other hand, takes the position
that probationary employees are only credited with seniority equal to the two-
year probationary period required by the collective agreement and, in the case of
the grievor, this two-year period was not completed until December 31, 1989,
because of its interruption by reason of her pregnancy leave.
The relevant provisions of the collective agreement are set out below. We
realize that other provisions were referred to in argument but, in the
interpretation of a collective agreement as detailed as this one, little weight
can be placed on language used to deal with issues quite different from those
presented by the grievance. In this case we are faced with the specific issue of
whether probationary employees are entitled to seniority credit while on
pregnancy leave and in resolving this issue it is necessary to focus upon those
provisions dealing with the seniority status of probationary employees and the
accumulation of seniority while on leave of absence. These provisions are found
in article 8 of the collective agreement.
Article 8 -- SENIORITY
8.01(a)(i) A full-time employee will he on probation until the completion of the
probationary period. This shall be two (2) years' continuous employment except
as described hereafter.
8.01(a)(ii) The probationary period for the following will he one (1) year's
continuous employment:
(a) a full-time employee who has completed a probationary period at the same or
another Ontario College of Applied Arts and Technology, and is hired by the
College in the same classification which the employee held during the
previous probationary period.
(b) a full-time teacher who bolds one of the following professional
qualifications and who has one year or more of full-time teaching experience
in Ontario:
(i) a valid Ontario Teacher's Certificate~
(ii) Bachelor of Education Degree;
(iii) Master of Education Degree.
(c) a full-time counsellor who holds one of the following professional
qualifications and who has one year or more of full-time counselling
experience in an educational institution in Ontario:
(i) a valid Ontario Guidance Specialist's Certificate~
(ii) Master's degree in Counselling or Guidance.
(d) a full-time librarian who holds a Bachelor's Degree in Library Science or a
Master's Degree in Library Science and who has one year or more of full-time
experience as a professional librarian in Ontario.
8.01(b) The probationary period shall also consist of twenty-four (24) full
months of non-continuous employment (in periods of at least one (1) full month
each) in a forty-eight (48) calendar month period. For the purposes of this
paragraph, a calendar month in which the employee completes fifteen (15) or more
days worked shall be considered a "full month".
If an employee completes less than fifteen (15) days worked in each of the
calendar months at the start and end of the employee's period and such days
worked, when added together, exceed fifteen (15) days worked, an additional full
month shall be considered to be completed.
8.01(c) On successful completion of the probationary period, a full-time
employee shall then be appointed to regular status and be credited with seniority
equal to the probationary period served.
8.11 A full-time employee shall continue to accumulate seniority for the purpose
of this Article while:
(a) in the College's active employ;
(b) absent through verified illness or injury and/or leave of absence for up to
twenty-four (24) months~
(c) on a College-approved leave of absence on an exchange program~
(d) on a College-approved professional development leave of absence;
(e) on a College-approved secondment for up to twenty-four (24) months.
Our starting point is article 8.11 of the collective agreement. That
provision clearly provides that a full-time employee continues to accumulate
seniority while on a leave of absence for up to twenty-four months. Pregnancy
leave is provided by article 17.02 of the agreement so it would appear at first
glance that the grievor, as a full-time employee, should be given seniority
credit for the period of her pregnancy leave.
Counsel for the employer, however, took the position that article 8.11 did
not,apply to probationary employees. He argued that, since probationary
employees had no seniority, it was not possible for them "to continue to
accumulate seniority" as contemplated by article 8.11. According to this
argument, a probationary employee was instead only entitled to be credited with
seniority equal to the'probationar~ period served once the probationary period
has been successfully completed by virtue of article 8.01(c).
The distinction that counsel attempted to draw appears to be one without a
difference. The fact that probationary employees receive no credit for seniority
until the successful completion of the probationary period, in our view, does not
necessarily mean that they cannot continue to accumulate seniority as
4
probationary employees. It is clear that the parties contemplated that
probationary employees would be given seniority credit for their service during
the probationary period and this seniority credit continues to grow, or
accumulate, during the probationary period. This accumulated seniority is then
credited to the employee upon successful completion of the probationary period·
Article 8.11 standing alone, therefore, appears to include both probationary and
regular full-time employees within its embrace.
Counsel for the employer, however, argued that article 8.11 must be read in
conjunction with articles 8.01(a) and 8.01(c). The former article stipulates a
probationary period of two years "continuous" employment, while the latter
provides that a full-time employee appointed to regular status is only to be
credited with seniority equal to the probationary period served. Counsel argued
that this requirement of two years continuous employment meant two years of
active service so that the grievor could only be given seniority credit for
.active service during her probationary period.
The difficulty with this argument is that, as counsel conceded, there was no
break in the grievor's employment with the College during her pregnancy leave.
At all relevant times the grievor continued to be an employee of the College even
though she did not perform her normal duties during the period of pregnancy
leave. Based on the plain meaning of article 8.0i(a) we can only conclude that
the pregnancy leave did not interrupt the grievor's probationary period so that
this period expired on August 31, 1989. At that point she should have been given
credit for the two years of seniority that had accumulated during her
probationary period and, from that point onward, she should have been treated as
a regular employee for the purpose of the calculation of seniority.
5
In reaching this conclusion we understand the employer's concern that,
because of the grievor's pregnancy leave, there was less opportunity for an
assessment of the grievor's performance as a probationary employee. If there is
any doubt about a probationary employee's work performance, however, there is
nothing to prevent the employer from reaching agreement with the union for an
extension of the probationary period. We should point out, though, that if the
probationary period were to be extended in this manner, the probationary employee
would still be entitled to seniority equal to the actual probationary period
served.
At the core of this grievance is the question of whether probationary
employees are to be treated differently than regular employees in respect of the
accumulation of seniority during pregnancy leave. The employer was quite candid
in conceding that regular employees continue to accumulate seniority while on
pregnancy leave. In the absence of clear language to the contrary we see no
justification for treating differently those probationary employees who
successfully complete the probationary period. This collective agreement
contains no such clear language and, accordingly, this grievance is allowed and
the employer directed to credit the grievor with seniority for the period while
she was on pregnancy leave.
We remained seized of this matter to deal with any difficulties arising from
the implementation of this award.
6
Dated at Kingston this C~)f~ day of October, 1990.
D.D. Car t~~
#.A. correll, Employer Nominee
I coneur/4io~eet ·
J. NcHanus, Union Nominee