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HomeMy WebLinkAboutWaffle 99-12-24IN THE MATTER OF AN ARBITRATION BETWEEN: ONTARIO PUBLIC SERVICE EMPLOYEES UNION (the "Union") AND - GEORGE BROWN COLLEGE (the "College") - AND - MARY GAZEL (the "Incumbent") AND IN THE MATTER OF THE GRIEVANCE OF G. WAFFLE OPSEU FILE #96D737 (ACADEMIC) BOARD OF ARBITRATION Robert D. Howe, Chair Larry Robbins, Union Nominee Rene St. Onge, College Nominee APPEARA/~CES For the Union Alick Ryder, Counsel Georgea Waffle - For the College Ann E. Burke, Counsel Ann Lillepold Michael Cooke Fo? tho Incumbcnt Mar~ Ga~=l Hearings in the above matter were held in Toronto, Ontario on June 3 and December 19, 1997; January 6, 7,. and 13, July 23, ? 28, and 29, September 15, and October 2, 1998; and February 1, September 16, and October 6 and 27, 1999. AWARD In his opening statement, counsel for the Union described the grievance which has been referred to this Board of Arbitration (the "Board") for determination in these proceedings as having the following three components: (1) an allegation that the grievor should not have been laid off because there is a junior employee (Mary Gazel) performing work which the grievor is fully qualified to perform; (2) an allegation that the College's obligation to give preference to continuation of full-time positions over partial-load, part-time, or sessional positions (under Article 27.05 of the Collective Agreement) was not met with respect to the staffing plan for the 1996-97 academic year; and (3) an allegation of an anticipatory breach of the grievor's recall rights, in violation of Article 27.09, based upon her being told that if she were to be recalled she would be recalled on a sessional basis. After hearing the submissions of counsel regarding the arbitrability of those three components (and Union counsel's request for an order directing production of on June 3, 1997: Having duly considered the submissions of counsel, we have reached the following conclusions: 1. The "anticipatory breach" issue referred to by Union counsel as issue %3 is not within the scope of the grievance and will not be heard by this Board of Arbitration. If such a breach occurs, a grievance can be filed in respect of it and duly dealt with in 1 accordance with the provisions of the Collective Agreement. 2. We have decided to reserve our ruling on the arbitrability of issue #2 (i.e., the full-time position preference issue), and to proceed to deal with issue ~1 (i.e., the lay-off issue). In making this decision, we have taken into account the fact that if the Union is successful on issue #1, the second issue might well be moot. If the Union is unsuccessful on issue #1, we will hear further submissions and, if necessary, evidence, regarding the arbitrability of issue #2. 3. We hereby order the College to produce reasonably in advance of the next hearing date all documents in the College's possession which describe the duties assigned to Mary Gazel during the 1996-97 academic year. During the course of these protracted proceedings, the Board heard detailed testimony from three witnesses: Georgea Waffle, the grievor; Helen Brown, the coordinator of the portion of the College's Personal Support Worker Program ("PSWP") fully funded by the Ministry of Health, who was previously a coordinator of the College's Home Support Worker Program ("HSWP"); and Georgia Quartaro, a Chair in the College's Faculty of Community Services, who at the time of the grievance was responsible for a total of twelve programs, including the PSWP (and its predecessors, the Health Care Aide Program ("HCAP") and the HSWP), and whose responsibilities as Chair included assigning teaching loads and preparing SWF's. In addition to the testimony of those three witnesses, the Board has before it twenty exhibits which were entered during the course of the proceedings. In making the findings and reaching the conclusions set forth is this award, the Board has duly considered all of that oral and documentary evidence, as well as the submissions of counsel. The Board 2 has also assessed what is most probable in the circumstances of the case, and considered the inferences which may reasonably be drawn from the totality of the evidence. The incumbent, Mary Gazel, was duly notified of these proceedings and was given full opportunity to participate in them. Although she elected not to testify, a considerable amount of 'evidence was adduced through other witnesses concerning her background, qualifications, and experience, as well as concerning her duties and responsibilities at the College. Ms. Brown, for example, provided the Board with the following summary in that regard: Mary Gazel is a nurse. She taught for many years in the HCAP. She coordinated the part-time HCAP. She arranged or supervised the field service for a large portion of the HCAP. She developed the beginning modules for our Level III program when that was developed. She was involved in many committees that brought her in contact with other agencies and government people like the Metro Home Care Program and the Ontario Community Support Association. She worked with the Alzheimers Society in developing our cognitively impaired program. She has taken training to be a trainer in HIV-Aids programing, and also to be a trainer in an experimental program called "Through Other Eyes". She served as a resource to our teaching group on many of those issues. Level III of the HSWP began as a single course called "Caring for the Cognitively Impaired". Ms. Gazel developed .............. t~hat-~ourse--i~---z~p-o~-e--t-o--~-~qU--~--I~6~--f~-~m~nit~'--t-~at ........ home support workers be trained to work with clients with dementia. She subsequently developed three additional courses in response to community requests for more specialized skills. Dr. Quartaro told the Board that she selected Ms. Gazel to develop those Home Support Level III courses "because she had 3 the knowledge of the HSWP as it was then being delivered, and had contacts with the community and a good sense of what the further training the community agencies were asking for would consist of." Ms. Gazel was also instrumental in developing the HSWP's Home Support for Health Care Aides stream, which was designed to address the needs of health care aides who wanted to expand their qualifications to include those of home support workers. During the 1994-95 academic year, she and Ms. Brown developed a program for Villa Charities (the "Columbus Centre Project") designed to train young people to be culturally sensitive Home Support Workers for the Italian community. The incumbent's Standard Workload Form ("SWF") for the period from September 3, 1996 to December 31, 1996 was entered as an exhibit at the behest of the Union, over objection by College counsel who contended it was of no evidentiary value since it did not reflect the duties and responsibilities actually performed by the incumbent during that period. That SWF was signed by Dr. Quartaro on May 6, 1996, and was signed by the incumbent two days later. The th~cc cou-~es---ii~b~d'-u~ it a~--CAK~-5~'CAR~ 5024, and CARE 5026. The complementary functions which it lists are "Departmental or Divisional Meetings", "Promotional Meetings", and "Co-ordination Of Home Support". SWF's covering the -' periods from January ~, 1997 to March 7, 1997 and from March 10, 1997 to July 4, 1997 were also entered as exhibits. 4 However, they were not prepared until 1997. At the request of Union counsel (who was proceeding on the assumption that College Counsel would argue that the Board should find the incumbent's position to be comprised of all of the duties and responsibilities which the incumbent actually performed during the 1996-97 academic year, regardless of when they were assigned to her), a list of the duties which the incumbent actually performed in 1996-97 was prepared by the College and entered as an exhibit in these proceedings. It includes the following information regarding the incumbent's actual duties and responsibilities during the period from the start of September to the end of December of 1996: Sept. - Nov. -CARE 9008 x 2 Level II for Health Care Aides "Health & Illness', -CARE 5026 x 2 Level III for Health Care Aides "Caring for Persons who are Cognitively Impaired" -CA_RE 5026 x 2 Level III for Home Support Workers -CA_RE 5020 x 1 Level III for Health Care Aides "Conzmunication & Personal Work Skills" Workers Nov. - Dec. -C~E 5013 x 1 Level II for Home Support Workers Other duties: 1. Coordination, Planning and Teaching in a project with Scarborough Support Services for 5 training Private Home Day Care for the Elderly. Aug. 96 - March 97 2. Planning and Student Selection for project with Villa Charities for training youth as culturally-sensitive Home Support Workers. Sept. 96 - Feb 97 3. Assisting in coordination of the basic programs: Home Support Levels II & III and Home Support for Health Care Aides. e.g., tracking student attendance, attending meetings at Home Care Program. 4. Beginning Nov. 96, negotiations began for 2nd Personal Support Worker Pilot Project In explaining why some of the work actually performed by Ms. Gazel during the fall semester of the 1996-97 academic year differed from the work listed in the SWF, Dr. Quartaro testified that it was always difficult to predict in May what faculty members would be doing in September, except in a general way based on what was probable. It was also her evidence that at the time she issued that SWF, she did not know whether or not a second PSWP pilot project would be operating during the 1996-97 academic year. She further testified that timetabling for the HSWP was particularly complex because the courses ran for a variety of different time periods rather than for a semesterized sixteen-week period, and because many different cohorts of students went through the program simultaneously. Students in that program were generally employed in the field and came to the College two days per week or in other varying patterns. There would be about 200 students in the program at any given time, with an annual total of approximately 800 to 900 students comprising a total of between 30 and 40 cohorts. However, 6 this varied from year to year. Dr. Quartaro also told the Board: "To represent the teaching loads accurately on the SWF, we would need to have issued a new SWF every week or at least every two or three weeks. I could have done so, but it was not our practice. Our practice was to issue SWF's in advance of the semester indicating probable teaching loads, even though we knew that the exact configuration of courses and duties would probably be somewhat different." Ms. Brown also testified that SWF's were not often accurate in relation to the HSWP because the program changed rapidly. She testified that "in the spring when we did the SWF's we didn't know what courses we were offering in the fall, so we made a ~uess." She further testified that if the SWF's were to be kept accurate, they would have to have been redone "about every two weeks" The PSWP was an initiative which had been discussed for a number of years prior to its implementation. After the Ministry of Health (Long-Term Care Division), the Ministry of Education, and the Ontario Community Support Association decided to jointly develop new provincial training standards and a model curriculum for workers providing personal care and --suppor~--~c~iccs~-pc~op~e--l~vin~ in ~u~-t~£ttt car~'Ta-c'i~t~e-S ........... and in their homes, a group called the Training Resource Group was established with representation from clients/consumers, workers, employers, unions, educators, and related professions. The Training Resource Group began meeting in January of 1993, produced a number of draft documents that 7 were reviewed by external reviewers (including Ms. Brown and Dr. Quartaro), and produced a detailed draft report in July of 1994. The PSWP is a single training program that consolidates and replaces the HCAP, which was established in the late 1970's to train health care aides who provide basic health care and other support services to clients in long term care facilities such as nursing homes, and the HSWP, which was established in the 1980's (as a successor to the Homemakers Program) to train home support workers who provide basic health care and other support services in clients' homes. In describing the purpose of the initiative which ultimately led to the establishment of that cOnsolidated program, Ms. Brown stated: There was feeling in the community that too many people were entering people's homes to do different tasks. It would be easier for the client if one person could do more tasks. It would be cheaper for the government to make more use of an unregulated worker, and there was already a lot of cross-over between health care aides and home support workers so it made sense to bring those two together. Personal Support Workers are trained to provide basic health care and support services in long term care facilities and in clients' homes. The range of services they provide depends upon the individual needs of each person they support and can include home management (such as shopping, house cleaning, and meal preparation), personal care (such as dressing, personal hygiene, mobility, and other routine activities of living), family responsibilities (such as routine care giving to children), and social and recreational 8 activities. After the Training Resource Group produced the aforementioned draft report, Personal Support Worker pilot projects were run at seven institutions, including George Brown College, to further explore the feasibility of introducing that consolidated program. When Dr. Quartaro became aware in the late fall of 1995 that the College had been selected as one of the locations at which a PSWP pilot project was to be run, she assigned Ms. Gazel to coordinate the pilot project and to be the lead teacher in it. She listed Ms. Gazel's duties and responsibilities regarding the pilot project as follows during the course of her testimony: - to organize the delivery of the pilot - to be involved in student recruitment - to come up with a plan for the delivery with herself and other teachers; I expected her to be the lead teacher, but I didn't expect her to teach all of it. - to find a practicum location so the students could do their institutional placement and to negotiate with the institution which was a delicate matter; for example, how many students would come, the day that they would come, what work they would do, what the College was expecting the students would learn while they were there, what support and supervision we would expect from the agency, and how the students would be evaluated. She also needed to maintain involvement with the people administering the pilot project, and primarily would need to be involved in the evaluation of the pilot at thc cnd. That mcar~ -notin9 l~e~ uwn ubse~vat~ons and also capturing the feedback from other teachers and from students so that we could be as helpful to the evaluator as possible. She also gave the following testimony when asked why she selected Ms. Gazel to perform those duties and responsibilities: Because Mary Gazel had a singularly appropriate 9 background for this. She had experience teaching the HCAP and knew that program well, and through her work coordinating the continuing education sector of that program she had current knowledge of the field and the agencies. She also had experience in the HSWP. She had experience designing and developing curriculum. She developed the Level III HSWP curriculum and had also been instrumental in developing the Home Support for Health Care Aides stream in the HSWP. That was really the first piece of cross-over training that we'd done in a formal way, and it was clear that if a PSWP came into being we would be doing a lot of cross-over training of that sort. Mary Gazel is also a diplomatic person, and I thought she would be able to work well with the agencies sending students and with the staff where students did their placement, who might be very apprehensive about these new students. The pilot required a lot of expertise but it also required something of a sales job - some ability to get people on board about something new that was unsettling. The first pilot project ran from December of 1995 to March of 1996. With the assistance of the model curriculum outline which accompanied the aforementioned draft report, Ms. Gazel prepared the course outlines and other materials used to teach that pilot project. Although other teachers delivered parts of the program, she taught much of it herself, and also carried out the other duties and responsibilities described above. Dr. Quartaro chose the faculty for the first pilot project. The grievor was teaching in the HSWP at the time of the first pilot project, but was not chosen to part~cip~t~ ~ that project. Dr. Quartaro provided the Board with the following explanation of why she did not choose the grievor: Because she was relatively new to the department and still becoming accustomed to delivering the HSW content, and I wanted people who were very comfortable and experienced in delivering that content. She also had very little community experience and that was the key in the Home Support Worker Program. I wanted a group of people who could work together well and 10 flexibly, so we could deliver the pilot project well and also develop good feedback. In November of 1996 the College was selected as the sole site at which a second Home Support Worker pilot project was to be run, commencing in February of 1997. Since she was very pleased with the manner in which Ms. Gazel had successfully run the first pilot project, Dr. Quartaro assigned her to play a similar key role regarding the second pilot project. She also gave her that assignment because she anticipated that the PSWP would come into existence, and wanted to draw upon her expertise and advice concerning how best to move from having two quite different programs to having a single program with three distinctly different delivery models (i.e., one for full-time fees paying students, another for continuing education students who would take the courses on a part-time basis over a longer period of time, and a third for persons employed in the community who would take the courses in varying patterns, such as two days per week). Late in the summer of 1997, the College was notified that the HCAP and PSWP would be cancelled as of September 1, 1997, and that they would be replaced by the PSWP. When Dr. Quartaro decided to give the grievor notice of lay-off in February of 1996, she anticipated that the PSWP would probably be introduced at some point in the future, but she did not know when. During cross-examination, she acknowledged that she wanted to be sure to retain Ms. Gazel because she was the best person to be involved in implementing the PSWP when it was approved. However, she also gave the 11 following testimony regarding that decision: Q. As the Chair, you see your role as Selecting the best for the College in terms of staff? A. Certainly I see my role as selecting the best staff for the College when we're in a hiring position. That's not the position we were in. We were in a bumping position. I was looking at the qualifications of the people we had. Q. But your decision enabled you to retain the best? A. Yes it did. Q. That is your objective as a Chair, to whenever possible retain the best? A. My objective as a Chair is to deliver high quality programs. That includes having qualified staff. During re-examination on that matter, Dr. Quartaro testified that in bumping situations "the question is not whether the person is the best person for the job, but whether they are qualified for the job". She further testified that her decision to lay off the grievor and retain Ms. Gazel was based upon her conclusion that the grievor was not qualified to do Ms. Gazel's job. That view was also shared by Ms. Brown. The grievor received her initial health care training during 1965-66 in the Nursing Assistant Program at Scarborough General Hospital, from which she received a Nursing Assistant Certificate. She then wrote provincial examinat~on~ ~o become a Registered Nursing Assistant ("R.N.A."), and worked in that capacity in the Hospital's paediatric unit from July 1966 to February of 1970. From February of 1970 to March of 1972, Ms. Waffle worked as an R.N.A. at a residence operated by the Metropolitan Toronto Association for the Mentally Retarded, where she obtained a Certificate in Residential Training, 12 developed knowledge and understanding of the needs of developmentally delayed persons through work experience and classroom training, and became involved in fund-raising and activities related to the Special Olympics. During the period from April of 1972 to May of 1978, she gained additional paediatric nursing experience as well as adult nursing experience by working as an R.N.A. at the Hospital for Sick Children, Sunnybrook Health Science Centre, and Princess Margaret Hospital. She became a Registered Nurse ("R.N.") in 1978, after completing the Diploma Nursing Program at George Brown College. She engaged in full-time and part-time general duty nursing on a variety of units at the Hospital for Sick Children from July of 1978 to April of 1990. While working there, she also began to take courses at York University (Atkinson College) as a part-time student majoring in health studies, and graduated with a Bachelor of Arts in the spring of 1995 (through courses taken at York and Ryerson). She then enrolled in a Master of Education program at Brock University, and by the spring of 1996 had completed the first two courses in that program. From March of 1988 to June of 1990, the grievor was cm~l-sycd as a part-time"teat-hei-~at the Re~iun~l Suhool for ...... Nursing Assistants operated by the Ministry of Colleges and Universities. Although that position primarily involved facilitating students' clinical training in long term care facilities and acute care hospitals, it also involved some classroom teaching of nursing theory when the grievor was 13 called upon to replace an absent teacher. During the fall/winter semester of 1989-90, the grievor was a part-time lead clinical teacher in Seneca College's Diploma Nursing Program, providing students (who were in the fourth semester of that six-semester program) with clinical learning experiences in the paediatric units of York-Finch Hospital. In September of 1990, the grievor commenced employment at George Brown College as a full-time professor. She was hired to teach in the Nursing Assistant Program (currently known as the Practical Nursing Program). Students entering that program must have graduated from Grade 12, unless they are accepted into the program as mature students. During the 1990-91 and 1991-92 academic years, she served as a clinical teacher for students throughout that nine-month program, and also taught classes in growth and development, and in human behaviour. She developed and supervised a preceptorship program, by liaising with nine hospital and community health care facilities for the provision of diverse pre-graduation experiences for students through preceptors (i.e., staff members serving as ~uides to students performing work at those hospitals and other facilities). She also .......... l-iaiscd--w~th rep~es~L~Live~Uf~r~e-lve ~h-i£~-care agencies to organize early childhood observational experiences for first semester students. She participated in the development of a combined nursing/nursing assistant entry level semester, and served first as a member and then as the chair of the committee responsible for developing the curriculum for that 14 combined semester. When that combined semester was implemented in the fall of 1993, she was the only faculty member from the Nursing Assistant Program assigned to teach in the combined program. The grievor taught at Centennial College during the 1994-95 academic year, after being laid off by George Brown College and grieving that lay-off. (That grievance was resolved by means of an exchange arrangement under which the grievor was temporarily transferred to Centennial, where she taught as a sessional while retaining her full-time status at George Brown College.) While at Centennial College, she taught in the first semester combined nursing program, and also in the "flex program" upgrading R.N.A.'s to R.N.'s. In addition to teaching an introductory communication course in a classroom setting, she provided students with a variety of clinical learning experiences. She was also involved in curriculum development, interviewing stake-holders within community agencies and incorporating their needs assessments into a more versatile and community-oriented nursing program. In June of 1994, Ms. Gazel was the successful applicant for a posted position of professor in the HSWP. her way to Centennial College (as a result of the first lay-off notice and grievance referred to above). After receiving another lay-off notice from George Brown College in the spring of 1995, the grievor was reassigned to the HSWP in the Faculty of Community Services, ~ 15 where she taught Health and Personal Care - Level II (focusing upon aging, chronic illness, and communicable diseases, as well as hands-on personal care skills necessary for providing support care in the home)); Advanced Personal Care - Level III (which incorporated a review of the Level II content, and further educated students in the methods necessary for providing optimum care in the home); and The Client with Cognitive Impairment - Level III (which facilitated the development of student understanding of the challenges facing Alzheimer clients and their families). Since many of the students in the HSWP program were previously untrained, non-professional health care providers whose first language was not English and who came from diverse cultural backgrounds, the grievor developed improved preparation and organization skills, improved strategies in conflict resolution, and adjusted teaching strategies and methods of presentation to facilitate the students' learning and their development of positive attitudes in caring for clients. Teaching "The Client with Cognitive Impairment" also necessitated research and additional preparation for teaching course content with which the grievor was unfamiliar prior to teaching at the Columbus Centre, where she found it necessary to further adjust her teaching strategies, testing methods, and evaluation for the particularly challenging group of students she encountered there, with very weak English skills and extremely limited knowledge and experience in Canadian 16 health care and culture. By letter dated February 27, 1996, the College (through Michael Cooke, the Academic Dean of the Faculty of Community Services) gave the grievor formal notice that, effective May 27, 1996, she was going to be laid off from the College as a result of her position as a full-time professor becoming redundant due to budget restraints. On March 14, 1996, Ms. Waffle filed the grievance which ultimately gave rise to these proceedings. In February of 1996 when the grievor received that lay-off notice, Ms. Gazel was heavily involved in the first PSW pilot project, performing the duties described above. She was also the HCAP continuing education sector coordinator, which was a role that she had been performing for several years. She was also assisting in the coordination of the Home Support for Health Care Aides stream of the HSWP, and assisting Ms. Brown in coordinating other aspects of the HSWP (because Ms. Brown was being treated for a serious illness which necessitated a substantial reduction in her teaching hours, and in the stress and time involved in performing her duties as a coordinator). There was no formalized division of __ du%i~_ili~th~ lattmr rol~, and~--M.~-~zct did-to-assist Ms. Brown changed from time to time depending on what there was to be done and upon how ill Ms. Brown was at various times. Ms. Gazel did most of the external committee work and also handled day to day problem solving regarding student issues and agency issues when Ms. Brown was not at the 17 College. Unlike students in many of the College's other programs who enrolled themselves in a program and paid tuition fees for it, students in the HSWP were employed by community agencies through funding provided by the government, which also provided the students with a daily living allowance. The coordinator's duties for that program involved liaising with the community in various ways including representing the College on community committees; discussing student selection, student progress, and other student issues with community agencies; and acting as a resource person for community agencies. Those duties also included meeting with the Ministry of Health's liaison person from time to time. Ms. Gazel also vetted the health care aide certificates held by HCA's who wished to upgrade to HSW's through the Home Support for Health Care Aides stream of the HSWP. This vetting had been performed by Ms. Gazel for a number of years, and was necessary to determine whether the pro,rams which they had completed at other institutions (including many located in other parts of the world) were equivalent to the College's HCAP. Although Ms. Brown did some of that vetting, even before her illness necessitated her -sccki-ng-add~lional- as~i~L~nu~ £~S. Gazel in cO~rdih~in9 the HSWP she often took questionable HCA certificates to Ms. Gazel for vetting because Ms. Gazel had more experience with that than she did. - Article 27.06 of the Collective Agreement provides, in part, as follows: 18 When the College decides to lay off or to reduce the number of full-time employees who have completed the probationary period or transfer involuntarily full-time employees who have completed the probationary period to another position from that previously held as a result of such lay-off or reduction of employees, the following placement and displacement provisions shall apply to full-time employees so affected. Where an employee has the competence, skill and experience to fulfill the requirements of the full-time position concerned, seniority shall apply consistent with the following: (i) An employee will be reassigned within the College to a vacant full-time position in lieu of being laid off if the employee has the competence, skill and experience to perform the requirements of a vacant position. (ii) Failing placement under 27.06 (i), such employee shall be reassigned to displace another full-time employee in the same classification provided that: (a) the displacing employee has the competence, skill and experience to fulfill the requirements of the position concerned; (b) the employee being displaced has lesser seniority with the College. One of the primary matters in dispute between the parties is the issue of what constitutes the incumbent's "position" for the purpose of determining whether the grievor has the "competence, skill and experience to fulfill the requirements of the position concerned", as required by Article 27.06(ii) (a). In his submissions addressing that issue, Union counsel contended that to determine the position to be displaced, the Board should consider the duties and responsibilities assigned to the incumbent as of the date the grievor's .lay-off became effective (i.e., May 27, 1996), and 19 should exclude from consideration any work which was assigned to the incumbent after that date. (As indicated below, he also contended that the incumbent's continuing education coordinator duties should be excluded from consideration.) He further submitted that the SWF issued to the incumbent in early May of 1996 for the fall semester of 1996 is the best evidence of the duties and responsibilities which had been assigned to the incumbent as of that time. Although Union counsel anticipated that counsel for the College would argue that the Board should consider all of the duties which the incumbent actually performed during the 1996-97 academic year regardless of when they were assigned to her, the argument which she actually advanced was that the Board should follow the approach adopted by arbitrator Carter in St. Clair College and OPSEU, (grievance of K. Barei, OPSEU File No. 88C427 - preliminary award dated May 15, 1989 (reported in 6 L.A.C. (4th) 442); (unreported) final award dated October 17, 1989), and determine the core pattern of duties and responsibilities performed by the incumbent during the course of her employment. She also referred the Board to a number of subsequent awards and submitted that arbitrator Carte-r-~-s-~pp£~ac~=~1~ ~~red by many other arbitrators without disagreement concerning his description of the position to be analysed. In replying to that argument, Union counsel submitted that the approach adopted by arbitrator Carter has been rejected in a number of subsequent cases and is no longer the 20 law. He contended that the .caselaw says that the position to be considered for displacement purposes is the position as of the date the lay-off becomes effective, and reiterated that the aforementioned SWF is the closest evidence of assignments for that purpose. In the two aforementioned St. Clair College awards, a board chaired by arbitrator Carter was called upon to interpret what was then Article 8.05, the material portion of which was substantially similar to Article 27.06(ii), as quoted above. In order to expedite the hearing of that matter, it was decided that the board should issue a preliminary award setting out their understanding of the intent and meaning of that provision, and then proceed to deal with the merits of the grievance to determine if there had been a breach. The board's unanimous preliminary award (dated May 15, 1989) includes the following observations (at pages 6-7) regarding what constitutes "the position" for the purposes of that provision: ... As we read this language [Article 8.05] it expresses an intention that the competence, skill, and experience of the displacing employee be measured against the benchmark of the content of the position being claimed. The problem, however, is to define the content of that position in an objective manner so as to-"~C~ih ~nb~h~--I~6~f~-u~o~ a balance between respect for seniority and recognition that an employer is not required to re-organize its work assignments to accormmodate the particular qualifications of a more senior employee. In situations where job content is not well defined, as in this case, this task can pose considerable difficulties. In the board's view, what one must do in this kind of case is to determine the core pattern of duties and responsibilities performed by an incumbent teacher during the course of her employment. It is this core 21 pattern of duties that forms the content, of the position against which the competence, skill, and experience of a displacing employee must be measured. If it can be established that a displacing employee is capable of performing the core pattern of duties and responsibilities being performed by an incumbent with less seniority, then under the terms of article 8.05 this incumbent would be displaced.· In determining this core pattern of duties and responsibilities, however, it is not sufficient to take a snapshot of the duties and responsibilities of the incumbent at just one point in time. Not only may some of the duties change from semester to semester, but some may also be peripheral to the central core of duties. Rather, what we must do is examine the actual work assignments given to an incumbent over an extended period of time to identify the basic pattern of duties and responsibilities performed by that incumbent. It is this core pattern of duties that make up the "position" and provides an objective standard against which to measure the competence, skill, and experience of the displacing employee. In the final award (dated October 17, 1989), arbitrator Carter summarized the conclusions reached in the preliminary award as follows, at page 3: In an earlier award we reached the conclusion that this provision, which had been amended in the last round of negotiations, no longer contemplates a competition between the displacing employee and the person presently holding the position. Rather than comparing the competence, skill, and experience of these two employees, it is now necessary that the qualifications of the displacing employee be measured against the content of the position being claimed. This exercise, however, is by no means easy since the content of the job must now be determined in an objective manner and not simply by reference to the qu_al~f~c~t~ons~ _khe--~cu__~_. What.m~e--donc, therefore, is to identify the core pattern of duties and responsibilities performed by an incumbent teacher during the course of her employment. Later in that award, arbitrator Carter added the following refinement to that approach (at page 4): In identifying this pattern, the more appropriate approach, in our view, is to confine our consideration to those courses that had been assigned to the 22 incumbent prior to the lay-off of the grievor. It is at the point of lay-off that the collective agreement requires the employer to put its mind to whether a displacing employee has the competence, skill, and experience to fulfill the requirements of the position. At this time, absent any precise job description, past assignments are the only concrete evidence of the responsibilities that define the position. While the College may have contemplated other assignments in the future, such future intentions are hardly an objective measure of what constitutes the position. Rather what must be looked to is the past pattern of assignments in order to establish an objective benchmark against which to measure the grievor's qualifications. The propriety of excluding from consideration future assignments which are made after the date of lay-off has been confirmed in a number of subsequent cases. See, for example, Niagara Colleqe and OPSEU (grievance of K.W. Martin, OPSEU File No. 88C730, award dated October 31, 1989) in which arbitrator H.D. Brown wrote, in part, as follows (at page 6): The question then is what meaning is to be given to "position" for the purposes of the application of Article 8.05(b). As the time for determination of the grievor's skill is as of the date of lay-off, it is the position held by the employee whom the grievor seeks to displace which is at issue. His position at that time is made up of a number of courses of teaching for which he is responsible and for which he has been assigned by the College as indicated in the SWF's. Courses of instruction which he may be subsequently required to teach are not then part of the position, although it is expected that as a full time Teaching Master, he will be required to teach for the full academic year. Nonetheless, his position for the purposes of the lay-off provisions is, we find, that which covers his .tcaching-assignments ~ of t~[~--'~'f-'-I~y-o~. After quoting from pages 6 and 7 of the arbitrator Carter's preliminary award in St. Clair College, and describing the reference which counsel for St. Clair College had made in that case to it being possible "to determine the content of the position based upon past experience, the award continued as 23 follows (at pages 7-8): That reference and the conclusion reached by the Board in that matter is significant in that it indicates that what is to be determined is the job content of the incumbent as at the date of lay-off together with the consideration of what had been the past requirements of the position. The Carter award did not define the position in terms of future teaching assignments which would not be set by the College at that time for the entire academic year. If that was to be the criteria, it would be possible to defeat the seniority rights of the laid-off employee by structuring future courses in a manner which would effectively prevent that employee from exercising the displacement rights under Article 8.05 (b) .... We conclude that this Article requires the grievor to have the requisite competence, skill and experience as at the time of lay-off. The "position" at that time is that which the incumbent fills with his responsibilities for teaching assignments at that time .... In that case, the board was only called upon to determine whether the grievor had to show that he had the ability to teach the incumbent's courses for both the fall and winter terms of the 1988-89 academic year, or for merely the fall term, as the College did not take the position that the position also included courses taught by the incumbent in the past. In Niagara College and 0PSEU (~rievance of William Mymryk, OPSEU File Nos. 88B943, 88B871, 88C149 & 88C152, award ---dat-ed--N~=mbcr--2~-, t989~at--pa~cs--3~-,~rbiL~L~-D~vlin expressed agreement with the approach set forth by arbitrator Carter in the aforementioned preliminary award,, subject to the exclusion of future teaching assignments (which, as noted above, is a limitation which was articulated by arbitrator Carter himself in the final award dated October 17, 1989): 24 ... In this case, the evidence indicates that when the College made its decision to lay off the Grievor, the teaching assignments for the winter term beginning in January of 1989 had not been made. This was also true when the Grievor received his notice of layoff on July 25, 1988 and when he subsequently filed his grievance in early August .... If this Board were now to consider [the incumbent's] position with reference to his teachin9 assignments during the winter term of 1989, we would, in effect be altering the nature of the position considered both by the College in making its layoff decision and by the Grievor at the time of the filing of his grievance. This, in our view, could not have been the intention of the parties and, for this reason, we are not prepared to consider the courses taught by [the incumbent] in the winter term of 1989 as relevant to the position sought by the Grievor. In St. Clair College and Ontario Public Service Employees Union, May 15, 1988 (Carter (unreported)), the Board was called upon to consider the meaning of the term "position" in Article 8.05. The board concluded that a "position" consists of. the core duties and responsibilities of the incumbent over a representative period of his employment. Subject to the qualification that this cannot extend to future teaching assignments for the reasons set out above, we agree that this is an appropriate standard against which to measure the skill, competence and experience of the Grievor. In this case, although the College introduced SWF's for [the incumbent] dating back to the fall of 1984, the evidence and argument of both parties were directed to the courses taught by [the incumbent] in the fall of 1988. In the absence of any submission to the contrary, we find that these courses were representative of the core duties and responsibilities of his position. other cases have also 'cOnfined their consideration to the incumbent's duties and responsibilities in the academic term in which the lay-off takes place. After reviewing the cases referred to above, arbitrator Burkett came to following conclusion in Fanshawe College and OPSEU (grievance of Leslie Dobos, OPSEU File No. 96F846, award dated June 4, 1998), at 25 pages 30-31: When reference is had to the foregoing jurisprudence under this collective agreement we are driven to the conclusion, for the same reasons articulated by arbitrators Brown and Devlin, that the "position" in respect of which a grievor must establish his/her ability under article 27.06 is the position occupied by the junior incumbent, comprised of the courses being taught during the term that the layoff is to be effective. This is not a surprising result given the competing interests that are at stake; the preference given to senior employees, for continued active employment, on the one hand, and, on the other hand, the College's need to have its course offerings taught by qualified professors. In the face of these competing interests it would make little sense to have the senior employee lald off to the street if he/she is capable of teaching the bundle of courses that the College has assigned to a junior employee at the time of the proposed layoff. Indeed, such a result, while it would not advance the interest of the College in having its course offering taught by qualified individuals, would undermine seniority rights. We reiterate that under this collective agreement, seniority operates to permit the senior employee to displace the junior employee in a layoff situation where the senior employee can establish that he/she has the "competence, skill and experience" to teach the bundle of courses assigned to the junior employee during the term that the layoff is to take effect. In Canadore College and OPSEU (grievance of J.P. Condon, OPSEU File No. 97D939, award dated November 26, 1998), arbitrator Swan made the following observations at pages 9-10:~ There has been some debate in the jurisprudence as to precisely which bundle of duties is to be used as the template against which an employee wishing to displace must be measured. In Re St. Clair Colleqe and ........ O~L~iu P--ul~lic Service ~ployees Unlon~-i~rei), 1989 6 L.A.C. (4th) 442 ('Carter), the template proposed was "the core pattern of duties and responsibilities performed by an incumbent teacher during the course of her employment". In later cases, such as Re Fanshawe College and Ontario Public Service Employees Union (Dobos), unreported, June 4, 1998 (Burkett) and Re George Brown College and Ontario Public Service Employees UniOn (McAuley), unreported, July 24, 1998, (Mitchnick), a much narrower "snap-shot" template is proposed, the position of the incumbent as it is comprised in the academic term in which the lay-off is 26 to take place. Arbitrator Swan found it unnecessary to enter into that debate, since the evidence in the Canadore case did not disclose any significant difference between the incumbent's anticipated assignment in the academic term in which the grievor's lay-off was to take place, and the pattern of the incumbent's assignments over the preceding four years during which the program had been in operation. However, he did find it "reasonable to exclude from consideration the special start-up functions performed by [the incumbent]" (including those pertaining to curriculum development and organization of an advisory council), because "[t]hose functions were spent by the time of the grievor's lay-off, and the only issue [was] whether the grievor was qualified to be left in charge of the maintenance of the structure already established." In determining the bundle of duties to be used as the template against which the grievor in the instant case is to be measured, it is appropriate to bear in mind the manner in which Article 27.06 operates. Displacement rights and obligations under that provision are exercised following a decision by the College to lay off but prior to receipt of w~ttenno-~%ce~f ]~-y~-of-f-~-a-nd--an-y--c-~mpl~i-nt--with--rcspcct to the exercise of those rights must be made within twenty days of receipt of written notice of lay.off: see Fanshawe ColleGe and OPSEU, (grievance of Shelly Masse, OPSEU File No. 96A080, unreported award dated June 25, 1998), in which arbitrator Burkett reached those conclusions after carefully analyzing 27 the language and structure of Article 26.07. Article 27.08 A of the Agreement requires the grieving employee to state in the grievance the positions occupied by full-time and non-full-time employees whom the employee claims entitlement to displace. That has been construed to be a mandatory substantive requirement, with failure by a grievor to comply being fatal to the success of the grievance: see Seneca College and OPSEU (grievance of Danny Vincent, unreported award dated February 6, 1998, H.D. Brown). If the grievance is referred to arbitration, Article 27.08 B requires that the written referral to arbitration specify two full-time positions (or positions occupied by two or more partial-load or part-time employees whose duties in sum will form one full-time position). However, the positions specified in the referral to arbitration must be selected "from the positions originally designated in 27.08 A". Thus, to comply with the requirements mandated by those provisions, a grievor must direct his or her mind at the time s/he receives notice of lay-off to his or her competence, skill and experience to fulfill the requirements of the position(s) held by the incumbent(s) whom the grievor seeks to displace. ........................................ t-f- -at~--the'-t-ime'~Ch-a u-a~' ~mPlO-y~- -i-S-- ~i~- ~6'~'i'~'- ~ ...................... lay-off a SWF has been issued setting forth the duties and responsibilities of the incumbent in the term that the lay-off is to be effective, it will generally be of considerable assistance to a grievor, and to an arbitration board, in determining the duties and responsibilities of the position. 28 However, in the instant case the incumbent's SWF for the 1996 fall semester is of little assistance for two reasons. Firstly, it did not come into existence until May of 1996, more than two months after the grievor received her notice of lay-off and filed her grievance. Thus, the grievor could not have relied upon it in determining what position(s) to name in her grievance. Secondly, it is clear from the totality of the evidence that the frequently changing nature of the HSWP program often rendered SWF's created in the spring inaccurate in respect of what actually occurred in the fall, and that keeping them accurate would have necessitated issuing new SWF's every two or three weeks. Consequently, the SWF, even if it had been available at the time that notice of lay-off was given to the grievor, would have been of little assistance in attempting to predict what the incumbent's duties and responsibilities would be during the term in which the lay-off was to be effective. Having carefully considered the jurisprudence summarized above, we have concluded that in a situation of constant flux and great uncertainty in which job content is not well defined, in which SWF's were unavailable at the time grievance was filed, and in which the SWF subsequently prepared would not be a reliable indicator of what the incumbent's duties and responsibilities would likely be in the semester in which the lay-off was to be effective due to the frequently changing nature of the HSWP program, the approach 29 applied by arbitrator Carter is preferable to the more narrow approach which has been adopted in some of the subsequent cases, as it is likely to provide a more accurate prediction of what the incumbent's duties and responsibilities will be in the semester in which the lay-off is to be effective and, accordingly, of what duties and responsibilities the grievor will likely be called upon to perform in that semester if she bumps the incumbent. Consequently, we have concluded that for the purposes of the instant case, the incumbent's position consists of the core pattern of duties and responsibilities performed by the incumbent during the course of her employment up to the time at which the grievor received notice of lay-off, with particular emphasis upon the duties and responsibilities that she performed after June of 1994 (when, as noted above, Ms. Gazel was the successful applicant for a posted position of professor in the HSWP). That core pattern includes teaching a variety of courses in the HSWP, including courses in the Home Support for Health Care Aide stream of that program; developing and implementing new courses and program streams, as exemplified by Home Support for Health Care Aides, Home teaching in external projects such as the Columbus Centre Project; and performing various HSWP coordination functions. It is well established in the arbitral jurisprudence regarding Article 27.06 that a grievor seeking to displace an incumbent must establish that s/he is immediately qualified to 30 perform the requirements of the position. See, for example, Fanshawe Colleqe and OPSEU (grievance of Leslie Dobos), supra, and Niagara College and OPSEU (grievance of K.W. Martin), supra. Article 27.06 does not provide for a grievor to be retrained or re-qualified before taking up the duties of the position. However, a grievor need not establish that s/he has previously taught each of the courses taught by the incumbent, as it is open to a grievor who lacks that specific teaching experience to nevertheless demonstrate her or his skill, competence, and experience by establishing that s/he has sufficient knowledge of the subject matter to fulfill the requirements of the position: see Niagara College and OPSEU (grievance of William Mymryk), supra, at pages 10-11. Moreover, the fact that the incumbent is better qualified to perform the position does not prevent a qualified senior employee from bumping into the position pursuant to Article 27.06. As noted by arbitrator Swan in Canadore College and OPSEU (grievance of J.P. Condon), supra, at page 10: ... it is not the ideal which the College would seek at the hiring stage that is the test of competence, skill and experience under clause 27.06, nor is it even the standard set by a particularly able incumbent. The test is whether the displaced employee can "fulfill the requirements of the position concerned". No doubt, ....................... givcn-thc--juxtaposition-o~hc--wordingv--..-it--was-int~nded that the displacing employee would fulfill those requirements competently and skillfully, at a level of quality which would reasonably permit the delivery of the program. It would not be enough merely to be able to go through the motions of performing the duties of the position, but it is not required that those duties be performed at a superior level established by a particularly qualified incumbent. 31 The grievor is an experienced and dedicated teacher who obviously has a deep interest in education. She has a solid nursing background, having trained and worked at a number of highly reputable hospitals and other institutions. She has also availed herself of continuing education opportunities by earning a Bachelor of Arts degree through courses taken at York University and Ryerson, and by pursuing graduate studies in education at Brock University. While some of those courses (such as Psychology in the Workplace, and The Child in Society: A History of Childhood and Child Welfare) are at most tangentially relevant to the issue of her competence to fulfill the requirements of Ms. Gazel's position, others (such as Psychology of Aging and Human Development) are more directly germane. Although much of the grievor's teaching experience involves clinical education in a nursing context, she has also taught classes in growth, development, and human behaviour in that context. Her teaching experience which is most directly relevant in the instant case is that which occurred during the 1995-96 academic year, in which she taught the following courses in the HSWP: Health and Personal Care - Level II (focusing upon agi~g~-ch-roni-c--i-ll~css~ and-~commun-ieablc-disc~scs¥--as--wct~-as hands-on personal care skills necessary for providing support care in the home); Advanced Personal Care - Level III (which incorporated a review of the Level II content, and further educated students in the methods necessary for providing optimum care in the~home); and The Client with Cognitive 32 Impairment - Level III (which facilitated the development of student understanding of the challenges facing Alzheimer clients and their families). As noted above, her workload during that academic year also included teaching at the Columbus Centre. We are satisfied that the grievor's teaching experience, in combination with her previous education and professional experience, gave her the competence, skill, and experience to perform part of the core pattern of duties and responsibilities performed by the incumbent, in that it enabled her to teach most if not all of the courses taught by the incumbent in the HSWP. However, we are not persuaded that the grievor had the competence, skill, and experience necessary to perform other key components of that core pattern, including the development and implementation of new courses and program streams of the type exemplified by Home Support for Health Care Aides, Home Support Level III, and the PSWP pilot project, and responding on an ad hoc basis to requests involving the planning and organization of external training projects. If the incumbent's involvement in such matters had .................. ~._!imi~d.._t~__.an_isolated_ins.t~n~,..~,ch_as~_the._spec~.a! ...................... start-up functions performed by the incumbent in the Canadore College case, we might well have been inclined to adopt the approach applied by arbitrator Swan of excluding it from consideration on the basis that it was spent by the time of the grievor's lay-off. However, the evidence in the instant 33 case clearly establishes that the incumbent had a regular and material involvement in such matters during the course of her employment, and that her involvement therein was likely to continue in the semester in which the grievor's lay-off became effective. Although the grievor had previously been involved in some curriculum and program development work (such as participating in the development of a combined nursing/nursing assistant entry level semester, and developing the aforementioned preceptorship program), that work was performed in the context of nursing education. Performing the new course and program stream development and implentation work of the type that the incumbent was regularly called upon to perform (as exemplified by that involving Home Support for Health Care Aides, Home Support Level III, and the PSWP pilot project), and responding on an ad hoc basis to requests involving the planning and organization of external training projects (such as the Columbus Centre Project) required a substantially greater depth of knowledge regarding the Health Care Aide and Home Support Worker Programs than the grievor possessed. It also required a broader range of contacts in the community served by those programs, program streams, and projects; 'a hi~he~-de~le~-o£ ~redibiIity-ih-'that"C~0~mmuh~t~ ................ and greater diplomatic skills. While we have no doubt that Ms. Waffle's subjective, statements of competence are based upon her sincerely held belief that she is qualified to perform Ms. Gazel's position, they do not discharge the burden of proof which lies upon the Union in these proceedings. 34 As noted above, counsel for the Union contended that the incumbent's coordinator duties for the continuing education sector of the HCAP should be excluded from consideration by virtue of Article 27.16, which provides: Extension and Continuing Education programs and courses which are not included in the regular assignment of full-time employees are excluded from the application of this Article for all purposes. In support of that contention, he referred the Board to Fanshawe College and OPSEU (union grievance re Article 4, unreported award dated June 28, 1996, H.D. Brown). College counsel, on the other hand, contended that Article 27.16 deals with the matter of whether a faculty member can acquire seniority based on continuing education teaching, and was not intended to exclude consideration of continuing education courses and duties in displacement situations. In the circumstances of the instant case we find it unnecessary to decide that issue, since even if that aspect of the incumbent's coordination duties is excluded from consideration, it does not change the fact that the grievor lacks the competence, skill and experience needed to perform significant aspects of the core pattern of duties and responsibilities performed by the incumbent, including the other coordination functions described above. For the foregoing reasons, we have concluded that the grievance cannot succeed on the basis of the first component described by counsel for the Union in his opening statement (i.e., the allegation that the grievor should not have been laid off because there is a junior employee performing work 35 which the grievor is qualified to perform). As indicated at the co~Lencement of this award, the Board ruled on the first day of hearing that the "anticipatory breach" issue referred to by Union counsel as the third component of the grievance was not within the scope of the grievance and would not be heard by the Board. However, we reserved our ruling on the arbitrability of issue #2 (i.e., the allegation that the College's obligation to give preference to continuation of full-time positions over partial-load, part-time, or sessional positions (under Article 27.05 of the Collective Agreement) was not met with respect to the staffing plan for the 1996-97 academic year), on the understanding that if the Union was unsuccessful on issue #1, we would hear further submissions and, if necessary, evidence, regarding the arbitrability of issue #2. Accordingly, we shall remain seised of the grievance for the purpose of dealing with that aspect of the case in the event that the Union decides to pursue it. DATED at Burlington, Ontario this 24th day of December, 1999. Robert D. Howe Ch a i r I concur. "Rene St. Onge" College Nominee 36 IN THE MATTER OF AN ARBITRATION BETWEEN: GEORGE BROWN COLLEGE and ONTARIO PUBLIC SERVICE EMPLOYEES UNION Grievance of Georges Waffle (~96D737) DISSENT I have reviewed the majority Award ir, this matter and regrettably must dissent from it. Thc Award does however fitirly summarize the detailed evidence which we heard over 11 days of hearings, (There were three further days devoted, to preliminary submissions and final argument.) My disagreement is with the legal test the majority have used in determining what in lhct the incumbent's position consisted of, and in the ultimate conclusions as to the grievor's qualifications. The Board was called upon to consider thc jurisprudence m~d rule over ',,,'hat exactly the , incumbent's position properly consisted of. For the purposes of this particular ease, the Chairperson has preferred the approach ol'Arbitrator Carter in St. Clair College 0May/89) {A¢.gr~, namely that one should consider the core pattern of duties and responsibilities performed by the incumbent teacher during the course of her employment. With thc greatest of respect, I disagree with that approach and prefer the approach of Arbitrators Bro_w. rt, [levlMand.Jtnrkett-(-Niag?ra-Cotleoe(OetJg9);-NiagaraC~'fllege(-Now./~9)m~d Fanshawe ....................... (;ollege(June/98)). In all three cases, the test they applied in determining the appropriate position was to consider the bundle or courses that the College had assigned to the junior employee at the time of the proposed layoff. As noted in the majority Awm'd however, all ofthe above awards appear to agTee that it is not appropriate for a Board to base its decision on what the incumbent actually did after the fact, Page 2 after the grievor was laid offand w~ r~quired to select the appropriate position for displacemont. Arbitrator Brown sets out why looking at what happens after the fact can lead to an un{air result: "The Carter award did not define thc position in terms oi'iilture teaching assignments which would not bc set by the College at that time for the entire academic year. If that was to be the criteria, it would be possible to defeat the seniority rights of tbs laid-offemployee by struct-aring future courses in a manner which would cftbctively prevent that employee from ~xercising the displacement rights under Article 8.05(b)." Applying this principle to our case, we must remember that the grlevor doesn't have the luxury. of wai'dag to see what happena after the fact. She must pick her position for bumping purposes within 20 days of receipt of notice of layoff. It would be manifestly unfidr if a position which she knew she could per£orm at the time were ~ansformexl into a position which was out of her reach whether by conscious manipulation by the Employer or even by the passage of intc~'ening events. For this reason, the fact that the 2"a Pilot Project actually took place during the 96/97 academic year should not be of any ~sistance to the College. The other point about the Carter Award which should be stressed is that he found that one should look at the core duties perfomaed by the incumbent, and not sweep in every dut3' the incumbent has performed in the past or else we run the risk of turning the test into a competition between the grievor and the incumbent. The Burkett Award (supra) is in my view the most relevant to our case bee, au.se in that ca.~ the Employer was in fact relying on the Carter approach, and pr~opo~sin~g t~o_ br~g in the who!e__pas_t .................... history, of the incumbent's employment. The positions of the Panics were there/i.~re similar to those before us in this ease. Arbitrator Burkett concluded as follows: "When reference is had to the foregoing jurisprudence under this collective agreement we are driven to the conclusion, for the same reasons articulaed b2 Page 3 arbitrators Brown and Dcvlim that thc "~sition" in respect of which a g~icvor must establish his/her ability under article 27.06 is the position occupied by the junior incumbent, comprised of'the courses being taught during thc term that thc layoff.is to be effective. This is not a surprising result given the competing interests that are at stake; the preference given to senior employees for continued active employment on the one hand, and, on the other hand, the College's need to have its course offerings taught by qualified professors. In thc face of these competing interest~ it would make little sense to have the senior employee laid off' to the street if he/she is capable of teaching thc bundle of courses that the College has assigned to a junior professor at the time of the proposed layoff. Indeed such a result, while it would not advance the interest of the College in having its course offering taught by qualified individuals, would undermine seniority rights. We reiterate that under this collective agreement, seniorit7 operates to permit the senior employee to displace the junior employee in a layoff situation where the senior employee can establish that be/she has thc "competence, skill and experience" to teach the bundle of courses assigned to the junior employee during the term that the layoff is to take effect." I would have reached a similar conclusion in figs case. The College laid offMs. Waffle, and she asserted a right at that time to btmlp the incumb¢llt effective thc fall/96 term. It is at thai point that she is clai~nlng that she can carry out the duties o£the incumbent. It is not necessary that she be able to perform all the duties carried out by the incumbent in the past over several' years of employment. Indeed in this case the incumbent had been in more than one position and had succ~ss£ully applied for a teaching position in thc HSW Program only in 1994. Moreover, most of thc course development and program dev~lopment duties referred to had already been complctext prior to the spring of 1996. It is true that during that term (Spring/96), Ms. G~elle was coordinating and teaching in th~ !". pSW_ pilot proj~ b_ut..that too_ w~as_, completedby thc time o£the ~icvor's ............ layoff: At the time of'the layoff', nobody kn~v if or when there would bca 2~ Pilot Project. As of May, 1996, based on the Minutes of the Home Support Advisory Committee, it was clear that there was no information on the future status of the PSW Program. Page 4 The college's best assessment of what the incumbent would be doing in the fall of 1996 was thc SWF which is described in full by the chairperson at Page 4 of thc Award, and which largely consists of courses which Ms. Waffle herself hud taught during the 1995/96 academic year. Chairperson rejects the approach of relying on the SWF tbr two reasons. First, he points out that the SWF itself was only dated and signed after the grievance was fried (but still betbre the grievor was actually laid off). Ia my view, this distinction should be of little importance. Although this document may not have been put to paper and signed as of February/96 ii is still the best evidence of what the incumbent's intended position was going to be. There was for example no earlier documenl that either pm'fy pointed to which conflicted with the above SWF. Secondly the Chair rejects the use of the SWF because of the changing nature of the program ~md the ['act that SWF's often turned out to be inaccurate. But, based on the evidence, even in this program, the SWF's were still a useful h~dicator. Ms. Quartaro testified that they were the College's prediction of what was generally probable. She agreed that it would have been more proper of the College to issue new SWF's to r~flect changes. But I don't agree that the c 'hanges were so &amstic ss to make the SWF's of no use. In my view, this decision, even though tl~ chai~rson restricts it to the circumstances of this ca.~, puts the griever in a ceD, difficult position. She still must elect the appropriate position tbr bumping within 20 days ofrecei~t o£notice of layoff. She would normally do so based on Mr best assessment of the incumbent's courses in the following term. It is unlikely that she will also ............. -~ ........ ; ............................... .- ............... · ................................................................. exmnme thc incumbent's past history, let alone determine which tasks constitute the core duties, even over a two or three year period, Moreover how is the grievor ~o know if this is an appropriate case for the Rrowu/Devlin/B~rkett approach, which is the normal approach, or if she must also meet the requirements of the Carter approach? I also am troubled by the maimer in which the ~ approach l~as been applied in this case. One must be very carci'ul ir~ assessing what in fa~t the cote duties of the incurabent consist of. In this ease, the Chairporson appears to sweep in most of the dttties the incumbent performed in the pas( into her core duties. In my view., the core duties of Ms. Gazelle more properly consisted of teaehi)~g courses in tho HSW Program, with some complementary and administrative functions. Had the 2"~ Pilot Project not taken place when it did, she may have in fact had very little in [he way of program development type functions during [he 1996/97 academic year. In ~ct, thc May/96 SWF makes no reference to any program development work. Finally on the chairperson's conclusions as to the grievor's qualification to perform the work of the incumbent, 1 would agree that she was qualified to perform the teaching functions. I would also have found however that she was qualified to carry out the administrative and proka'am and curricu)um development functions as well. As the chair has set out, she had performed such functions over the course of her employment at G~rge Brova~ Coll~ge and had even been thc chairperson of the curriculum committee with respect to the combined nursing/nursing assistant entry level semester. The evidence was that it is normal lbr faculty membe,~ to be involved in. curriculum development functions, and the grievor was no exception. In my view, the grievor was qualified to carry out such functions in the IISW Program based on her years of teaching experience generally and including her recent experience in the very same department. She may not have been able to perform these functions as well as thc incumbent, but of course that is not the test. In my view she had the competence, skill' and experience to fulfil the requirements of the position concerned, and I would have allowed the grievance on this aspect of the case on that basis. Page 6 DA~I~ AT TORONTO, this 24r" day of'December, 1999. Larry Robbins, ~D~nion Nomin'~-.---.~ -