HomeMy WebLinkAboutGroup 97-12-08IN THE MATTER OF AN ARBITRATION
BETWEEN:
MOHAWK COLLEGE
(The College)
- and -
ONTARIO PUBLIC SERVICE EMPLOYEES UNION
(The Union)
AND IN THE MATTER OF GROUP GRIEVANCES - #94A 443 & #94A444
BOARD OF ARBITRATION: Kenneth P. Swan, Chairman
Peter M. Hetz, College Nominee
Jon McManus, Union Nominee
APPEARANCES:
For the College: D.K. Gray, Counsel
Z. Ullah, Director, Human Resources
For the Union: David Wright, Counsel
Robert A. Pando, President, Local 240
Mike Walton, Chief Steward, Local 240
A WARD
This arbitration concerns two grievances consolidated by agreement of the parties.
Both are group grievances filed on November 30, 1993. Grievance 94A443 relates to post-secondary
faculty, while Grievance 94A444 relates to non-post secondary faculty. Both grievances relate to the
way that the College has applied unpaid leave days under the Social Contract Act, 1993.
Most of the facts on which this matter is to be determined are not really in dispute.
The Social Contract Act, 1993, had as its central purpose to reduce public sector compensation costs.
The Act was designed to encourage the negotiation of framework agreements for sub-sectors of the
public sector, and local agreements based on those framework agreements, which would then
effectively become part of the particular collective agreements between the local parties. In the
academic bargaining unit of the Colleges of Applied Arts and Technology, however, no local
agreements came into effect, and therefore the impact of the Social Contract Act, 1993 on the
employees affected by the present grievances comes only from the so-called "fall-safe" pro(,isions
found in Part VII of the legislation.
Specifically, sub-section 25(1) of the legislation provides that "an employer may
require employees to take unpaid leaves of absence" where necessary to meet the expenditure
reduction target established under the legislation. Sub-section 27(1) requires the employer, in certain
circumstances, to use unpaid leaves of absence as an expenditure reduction mechanism before other
actions to limit expenditures may be taken, and clause 27(1) (b) requires the employer to "develop
a program setting out the manner in which these leaves are to be implemented".
To expand somewhat the statutoo' basis for this requirement, Ontario Regulation
590/93, dated September 30, 1993, defined the relevant expressions as follows:
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5. In Part VII of the Act, "unpaid leave" and "unpaid leave of absence" mean a
leave of absence without pay that is,
(a) the whole of an employee's regular work day; or
Co) half of an employee's regular work day, if the half day of leave begins at the
beginning of the employee's regular work day or ends at the end of the
employee's regular work day.
Such a program was apparently developed centrally by the Ontario Council of Regents
for all of the colleges, and was then applied by the present college to its academic staff. The relevant
provisions of that program are as follows:
5. IMPLEMENTATION OF UNPAID LEAVES OF ABSENCE
4.1 Subject to 4.4, 4.5, 4.6 and 4.7, employees covered by this Program, except
employees referred to in 1.3, shall take 6 unpaid leave days during the period
commencing with the day of posting under section 29 of the Act and ending
March 31, 1994.
4.2 Subject to 4.3, 4,4, 4.5, 4.6, and 4.7, employees covered by this Program,
except employees referred to in 1.3, may be required to take up to 12 unpaid
leave days during each of the annual periods ending March 31, 1995 and
March 31, 1996.
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4.3 If unpaid leave days referred to in 4.2 are required, the number in each year
will be specified in amendments to this Program to which sections 30 and 31
of the Act will apply.
4.4 Employees who are hired by the Colleges and work less than any of the
periods ending March 31, 1994, 1995 and 1996, as referred to in 4.1 and 4.2,
will be required to take a prorated number of releVant unpaid leave days.
4.5 Employees who regularly work less than a complete year will be required to
take a prorated number of the relevant unpaid leave days.
4.6 For greater certainty, for the purpose of 4.4 and 4.5, the regular vacation
period shall be considered time worked.
4.7 In the calculation of the number of unpaid leave days, in order to ensure that
the annual earnings of an employee do not fall below $30,000.00, the number
of unpaid leave days required to be taken shall be reduced if necessary.
5. SCHEDULING OF LEAVES
5.1 Subject to 5.2 and 5.3, unpaid leave days will be scheduled by the Colleges,
taking into consideration the employee's wishes subject to operating
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exigencies. As far as possible, unpaid leave days will be scheduled with
mutual consent.
5.2 In the absence of mutual consent, College management shall assign the unpaid
leave days.
5.3 Notwithstanding 5.1, College management may schedule unpaid leave days
by specifying a specific day or days as a partial or complete shutdown for a
work unit.
5.4 Where the College elects to apply 5.3, employees described in 1.3 may, at the
election of the College, be paid for the day or days in question, assigned work
on the day or days in question, or reassigned other work days, so that their
earnings are not adversely affected.
By memorandum dated August 18, 1993, the College established three "corporate"
closure days on September 3 and December 24, 1993, and February 25, 1994. All of these days were
during non-teaching periods, in the sense that no classes were the scheduled. While some post-
secondary faculty were required to take an earlier day offrather than February 25, the day chosen was
also in a non-teaching period, so the same principle applies for all faculty in relation to the corporate
closure days.
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Beyond those three days, post-secondary teachers were allowed, if they wished, to
schedule the other three required unpaid leave days on days which would otherwise have been
teaching contact days. It appears, however, that no one did, and that all took non-contact days by
choice. Non-post-secondary faculty, however, were required to take the other three days off on non-
contact days. The grievances thus specify three days and six days respectively as the days on which
the Union alleges that the scheduling of unpaid leave constitutes a breach of the collective agreement,
even as modified by the Social Contract Act, 1993 and the fail-safe program developed pursuant to
that legislation.
A detailed correspondence subsequently ensued between the local Union and the
College. The Union took the position that non-contact days constituted ordinary working days for
faculty, involving work which was essential to the delivery of the academic program. In effect, the
Union argues that since the full academic program continued for non-post-secondary teachers insofar
as contact hours was concerned, and was largely continued for post-secondary teachers, an unpaid
leave day on a non-teaching day really meant a day on which the employee was unpaid, but could not
constitute a day of leave since all of the ancillary duties normally scheduled on a non-contact day in
support of the academic program would still have to be performed if the full program were to be
delivered on the contact days. Such work as preparation, marking, meetings, non-formal interaction
with students, professional development and course administration would all have to be carded out,
and since the academic program being delivered was unchanged, or largely unchanged, the same
amount of non-contact work would be required for its delivery.
The Union's evidence is that, although some faculty members attempted to negotiate
unpaid leave on contact days, ultimately all non-post-secondary professors took unpaid leave on non-
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contact days under protest, while post-secondary professors took contact or non-contact days at their
own discretion for the three days which were not specified as corporate closure days. The evidence
is that there was no corresponding diminuation of work equivalent to the unpaid time off. Non-post-
secondary professors were said to have conducted "business as usual" in order to achieve all of the
non-contact tasks required in support of a full load of contact days, and post-secondary professors
were said to have been required to deliver the same course content, with the associated non-contact
duties, even had they actually reduced the number of contact hours by taking an unpaid leave day on
a day which would normally have included teaching. In effect, therefore, the grievance is for overtime
work performed, whether on the unpaid leave days themselves or at some other time outside the
normal work schedule, in order to perform the work necessary to support the academic program
which would ordinarily have been performed on the unpaid leave days.
The College's evidence was to the effect that the College expected that no work of
any kind would be done on the unpaid leave days, and that no one was ever expected or required to
make up any work. No written directives were given as to what part of the normal workload should
be abandoned, because every faculty member would have a different schedule and a different mix of
non-contact duties to perform. The College lef~ the decision as to which duties should be abandoned
to individuals, and if any questions should arise those individuals could take them up with their
supervisors. No duties were reassigned, no specific reductions in course content were specified, and
no one was questioned or challenged as to the precise re-alignment of his or her own duties which
he or she decided to implement.
In the Apprenticeship Department, some correspondence was exchanged between
Union representatives and management on how unpaid leave days were to be scheduled. That
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ultimately resulted in a directive from management that professors, all of whom are non-post-
secondary teachers, should choose.one of their weekly non-contact days as an unpaid leave day, and
should "stay away from the college" on that day. No further direction was given, however, in relation
to re-allocation of the work which would normally been done on that day.
Article 11 of the collective agreement is a very detailed code, negotiated between the
parties, as to how teachers are to be assigned work. It is of some assistance to quote in full some of
these provisions:
11.01 A Each teacher shall have a workload that adheres to the provisions of
this Article.
11.01 B 1 Total workload assigned and attributed by the College to a teacher
shall not exceed 44 hours in any week for up to 36 weeks in which
there are teaching contact hours for teachers in post-secondary
programs and for up to 38 weeks in which there are teaching contact
hours in the case of teachers non in post-secondary programs.
The balance of the academic year shall be reserved for complementary
functions and professional development.
Workload factors to be considered are:
(i) teaching contact hours
(ii) attributed hours for preparation
(iii) attributed hours for evaluation and feedback
(iv) attributed hours for complementary functions
11.01 B 2 A "teaching contact hour" is a College scheduled teaching hour
assigned to the teacher by the College.
Clause 11.01 D includes a detailed formula for calculation of attributed hours for preparation, while
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11.01 E provides for the calculation of attributed hours for evaluation and feedback. 11.01 F
provides for a weekly allowance for certain complementary functions, specifically routine and out-of-
class assistance to individual students and normal administrative tasks.
Article 11 also provides for scheduling of. the assigned workload in the following
provisions:
11.01 G 1 Where preparation, evaluation, feedback to students and complemen-
tary functions can be appropriately performed outside the College,
scheduling shall be at the discretion of the teacher, subject to the
requirement to meet appropriate deadlines established by the College.
11.08 In keeping with the professional responsibility of the teacher, non-
teaching periods are used for activities initiated by the teacher and by
the College as part of the parties' mutual commitment to professional-
ism, the quality of education and professional development.
Such activities will be undertaken by mutual consent and agrekment
will not be unreasonably withheld.
Such activities will neither be recorded nor scheduled except as in
accordance with 11.01 G 1.
Finally, the class definition of the professor classification provides an overview of the
duties and responsibilities of members of the academic bargaining unit engaged in teaching which
lends some flavour to the arguments of the parties:
CLASS DEFINITION
PROFESSOR
Under the direction of the senior academic officer of the College or designate, a
Professor is responsible for providing academic leadership and for developing an
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effective learning environment for students. This includes:
(a) The design/revision/updating of courses, including
- consulting with program and course directors and other faculty
members, advisory committees, accrediting agencies, potential
employers and students;
- defining course objectives and evaluating and validating these
objectives;
- specifying or approving learning approaches, necessary resources, etc.
- developing individualized instruction and multi-media presentations
where applicable;
- selecting or approving textbooks and learning materials.
b) The teaching of assigned courses, including:
- ensuring student awareness of course objectives, approach and
evaluation techniques;
- carrying out regularly scheduled instruction;
- tutoring and academic counselling of students;
- providing a learning environment which makes effective use of
available resources, work experience and field trips;
- evaluating student progress/achievement and assuming responsibility
for the overall assessment of the student's work within assigned
courses.
c) The provision of academic leadership, including:
- providing guidance to Instructors relative to the Instructors' teaching
assignments;
- participating in the work or curriculum and other consultative
committees as requested.
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In addition, the Professor may, from time to time, be called upon to contribute to
other areas ancillary to the role of Professor, such as student recruitment and
selection, time-tabling, facility design, professional development, student employment,
and control of supplies and equipment.
The issues raised by the present grievances have been the subject of several other
proceedings, some prior to the hearing in this matter, and some concurrent with it. There are also
some decisions arising from similar disputes at other institutions which are also of some interest. We
propose to begin by reviewing that jurisprudence, to which extensive argument was directed by both
parties.
First, the Union aplSlied for a review under Part VII of the Social Contract Act, 1993
of the fail-safe program developed by the Council of Regents on behalf of all of the colleges. That
request was disposed of by a decision of the Office of Social Contract Adjudication established under
the Social Contract Act 1993 in Re Ontario Public Service Employees' Union and Ontario College
of Regents for Applied Arts and Technology, File 80 Adj-UCO003, July 13, 1994 0VlcKechnie, Chief
Adjudicator). A similar argument was put to the Chief Adjudicator as that before us, but the Chief
Adjudicator indicated that the program, as then posted, did not indicate any violation of the Social
Contract Act. Given the possibility of confusion possible for academic staff, however, his order
confirming the Program, required the following amendment:
The Employer is directed to amend the Program to reflect the mutual understanding
of the impact of unpaid days where workload by incorporating the following into the
Program: work in relation to an unpaid day is not expected or required either on that
day or subsequently.
This decision, of course, came after all of the unpaid leave days here at issue. In
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addition, at page 10 of the decision, the Chief Adjudicator made the following
observation:
If there is some confusion in this regard or if there are issues in which work has not
been reduced - that is, an unpaid day resulted in work being done on that day - this-
is a matter of implementation to be resolved pursuant to the grievance procedure
contained in the relevant collective agreement.
In Re Northern College of Applied Arts and Technology and Ontario Public Service
Employees' Union, Local 655, Workload Grievances, September 28, 1994 0Vlorrison), a workload
resolution arbitrator, whose jurisdiction comes from clause 11.02 of the collective agreement, was
presented with a workload grievance alleging that the assignment of Social Contract unpaid leave
days at that College, which was not materially different from the situation before us, was contrary to
the collective agreement. The workload resolution arbitrator declined to deal with unpaid leave days
assigned by the College during non-teaching periods, that is, outside of the normal academic ierms,
on the basis that his jurisdiction was limited to Articles 11.01 or 11.02, and the assignment of work
during non-teaching periods is covered by Article 11.08.
With respect to unpaid leave assigned on non-contact days during the teaching
periods, however, the workload resolution arbitrator took jurisdiction to deal with the issue. At pp.
9-11 of his decision, the workload resolution arbitrator distinguishes between assigned hours and
attributed hours, and comes to the'following conclusions:
I note the use of the words assigned and attributed. As I read the Social
Contract legislation, particularly subsections 25 (1), 33 (1) and 34(3), management has
the right to reduce teaching contact hours, since these hours are assigned to the
teacher by the College. But management does not have the unfettered prerogative to
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reduce attributed hours for preparation, evaluation and feedback, and for comple-
mentary functions - unless teaching contact hours are also reduced. My reasons are
as follows:
Preparation, Evaluation and Feedback
Articles 11.01 D 1 and 11.01 E 1 set out mathematical ratios of assigned teaching
contact hours to attributed hours for preparation, evaluation and feedback to students.
These ratios are a product of the collective bargaining process and represent a mean.
In some cases, professors will spend more time on preparation, evaluation and
feedback than is allotted to them by the formula, in other cases less. In all cases, ifa
teaching contact hour is assigned by the College, then professors have to prepare for
it, and they have to perform evaluation and feedback to students. For the College
simply to direct professors not to perform such activities, yet still assign them
teaching contact hours, would be to unilaterally revise downward the formulas
stipulated in 11.01 D1 and 11.01 E 1. The net effect, in most if not all instances,
would be an increase in workload.
Complementary functions
By Article 11.01 F, complementary functions appropriate to the professional
role of the teacher may be assigned to a teacher by the College:
Hours for such functions shall be attributed on an hour for hour basis5
An allowance of a minimum of five hours of the 44 hour maximum weekly
total workload shall be attributed as follows:
three hours for routine out-of-class assistance to individual students
two hours for normal administrative tasks
Like the preparation and evaluation factors, the attributive ratios set out in this
Article - including the three hours for routine assistance and two for normal
administrative tasks - are the product of the collective bargaining process. They too
represent a mean. If the parties estimate that it takes a certain number of hours to
produce a course outline, then that number of hours will appear on a SWF under
complementary functions. Sometimes the task will take more time, sometimes less.
Thus, it is not sufficient for the College to tell professors not to perform comple-
mentary functions on a given day if they still have to produce a course outline, or
assist individual students, or perform administrative tasks at other times of the week
or SWF period. The basic result is a transfer of work tasks from one period to
another.
In summary, the College does not have the unilateral right under either the
Collective Agreement or the Social Contract legislation to revise ratios and attribution
formulas which are the produce of the collective bargaining process. The College is
entitled to meet its expenditure reduction targets by requiring its employees to take
six days unpaid leave of absence. But those leaves must be genuine. That is to say,
they must result in a measurable reduction in work performed. While some of the
complainants have been assigned unpaid leave days during teaching periods, there has
been no reduction in teaching contact hours. I find, therefore, that the College has
violated Article 11.01 A of the Collective Agreement.
Two other awards were referred to by the Union in argument, Re Porcupine Area
Ambulance Service and Canadian Union of Public Employees, Local 1484, January 10, 1994
(Dumoulin) and Re Trent University and Canadian Union of Educational Workers, Local 8, May
16, 1994 (Starkman). The first of these deals with a factually different situation, but its rationale is
applied to a set of circumstances rather more like those before us in the second case. In both cases,
the arbitrators appear to have treated the issue as the assignment of an unpaid leave day which would
otherwise be a day when no duties would normally be assigned, so the cases may be distinguished at
least in part from the situation before us, where the collective agreement clearly contemplates the
assignment of duties, albeit not teaching duties, on ail of the days at issue.
It will be obvious that this is a very difficult question to resolve, and it is made even
more difficult because of the way in which it has been brought, as two group grievances involving a
large number of individual professors, each of whom has an individualized workload. On the face of
it, as the College argues, the assignment of unpaid leave days on days when no teaching contact was
scheduled, whether that is because the days fall outside of the normal teaching periods, or because
they are non-teaching days within the teaching periods, still fits squarely within the Social Contract
Act and Regulation 590/93. Unlike the Porcupine Ambulance Service case, and at least as we read
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the facts, the Trent University case, all of the days assigned, or chosen under protest, by the
professors covered by these grievances were regular work days, on which the professors would either
be expected to attend at work and perform duties during the usual hours, or in the individual
discretion of each professor perform duties outside the College pursuant to sub-paragraph 11.01 G
1.
As to the Northern College workload grievance award, to the extent that it relies on
the mathematical ratios between assigned teaching contact hours and attributed hours for
appropriation, evaluation and feedback, the award ignores the fact that those hours are only
attributed, and are not necessarily actual hours. Individual professors have a degree of flexibility
inherent in how they use the attributed hours, and when they actually perform the duties that are
associated with those hours. In short, while the relationship may be mathematical, it is not unyielding,
and does permit a certain scope for individual professors, however reluctantly, to reduce the amount
of time spent on these functions, or to move these functions to different times than when they would
normally have been performed.
In addition, there is a certain amount of slippage inherent in the complementary
functions, which are not related to teaching hours but are assigned during the week. While the three
hours assigned for out-of-class assistance to individual students may relate to factors such as the
number of teaching contact hours find class size, the two hours for normal administrative tasks, and
it should be observed that this is a minimum assignment pursuant to paragraph 11.01 F, are assigned
weekly, By a certain amount of individual scheduling of time, which the agreement clearly intends
should be let~ to individual professors apart from the requirement to attend actual classes, those
allowances could be cobbled together into a full day of"normal administrative tasks" which could
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then be lef[ undone.
Given the nature of employment of faculty members, and in particular the substantial
amount of individual initiative involved in allocating the time for which individuals are paid, it appears
to us that there would have been a far greater intrusion into the collective agreement had the College
taken upon itself to specify directly those aspects of the workload which should be abandoned and
those aspects which should be rescheduled because of the unpaid leave days.
In short, we have come to the conclusion, although with a considerable degree of
reluctance, that the application of the Social Contract Act and the fail-safe program to the academic
staffofthe College was not contrary either to the Social Contract Act, or to the collective agreement,
insofar as it relates to the generality of professors.
It may be that there were individual cases where a hardship arose because of the
particular assignment of unpaid leave days, and where a valid factual case could be made for the
payment of overtime. But on the evidence before us, no such general case can be made out which
can be applicable to all faculty members, and that is how the grievances were presented.
In the result, the appropriate resolution is to dismiss the grievances.
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DATED AT TORONTO this 8th day of December, 1997.
Ke~airman
I concur "Peter M. Hetz"
Peter M. Hetz, College Nominee
I dissent; see attached "Jon McManus"
Jon McManus, Union Nomine
12/01/97 16:09 FAX 15198696468 JOHN ~lC ~IANUS ~03
While
p~.
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~~.
ADDENDUM
Our dissenting colleague suggests that our reference to "a certain amount of slippage
inherent in the complementary functions" leads to the inference that professors are not really working
during the hours assigned for those functions, an inference which he calls insulting.
No insult is intended, nor was the inference which our colleague has drawn. We have
no doubt that professors work hard during the assigned hours, and often beyond them, on a range of
tasks ancillary to the course delivery enterprise, but important to the functioning of the College.
Since the College has elected not to reduce the course delivery function, other tasks would have to
be allowed to slide to match the total workload with the reduced pay created by the Social Contract
days. We only intended to suggest that there is room within the general heading of complementary
functions to find enough tasks to leave undone, over the course of the year, to achieve this match.