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HomeMy WebLinkAboutUnion 97-01-02BETWEEN: ONTARIO PUBLIC SERVICE EMPLOYEES' UNION (hereinafter referred to as "the Union") - and - SHERIDAN COLLEGE (hereinafter referred to as "the College") Union Grievances - Lay-offs Before: M.G. Mitchnick - Chairman M. Sullivan - Union Nominee J. Campbell - College Nominee Appearances: For the Union: C. DiFrancesco - Counsel N. Sibbick - President, Local 244 R. Martin - Chief Steward, Local 244 A. Kolisnyk - Union Member For the Employer: F. Hamilton - Counsel D. Borrelli - Executive Director Human Resources S. Bawden - Labour Relations Assistant Hearings held in Oakville on September 25th, October 29th and November 5th, 1996 PRELIMINARY AWARD I The present board has before it five grievances arising out of a very large-scale down-sizing by the College. Those lay-offs were discussed with the Union in the latter part of 1995, and notices went to the affected faculty members in February of 1996. The notices have spawned many dozens of individual employee grievances, none of which are before the board. What are before the board are five over-arching Union "policy" grievances, raising a variety of issues including the improper conversion of the teaching workload to part-time or sessional contracts, and, on a number of grounds, "discrimination". The College raises a variety of preliminary objections to the manner in which these policy grievances have either been filed or processed, and accordingly takes the position that none of them are arbitrable. It has been agreed that the present award would deal only with two of those objections by the College. Two of the Union grievances were filed on March 3, 1996, one on March lOth, and one on March 20th. All four of those were the subject of a combined Step 2 meeting that took place on March 20th. A reply to those grievances was prepared by the College, and "delivered" to the Union (in circumstances which will be discussed) on March 27th. The Union did not, however, receive the reply, and it was not until it inquired on April 23rd that it was advised that the College had already sent it. Upon receiving a further copy of the reply the Union referred it to arbitration immediately, but the College takes the position that by then the 2 referral was out of time. The relevant provisions of the collective agreement read: Union Grievance 32.10 The Union or Union Local shall have the right to file a grievance based on a difference directly with the College arising out of the Agreement concerning the interpretation, application, administration or alleged contravention of the Agreement ... Such grievance shall be submitted in writing by the Union Grievance Officer at Head Office or a Union Local President to the Director of Personnel or as designated by the College, within 20 days following the expiration of the 20 days from the occurrence or origination of the circumstances giving rise to the grievance commencing at Step One of the Grievance procedure. And thus more generally: Grievances 32.03 Failing settlement of a complaint, it shall be taken up as a grievance (if it falls within the definition under 32.12 C) in the following manner and sequence provided it is presented within seven days of the immediate supervisor's reply to the complainant. It is the intention of the parties that reasons supporting the grievance and for its referral to a succeeding Step be set out in the grievance and on the document referring it to the next Step. Similarly, the College's written decision at each step shall contain reasons supporting the decision. Step One An employee shall present a signed grievance in writing to the employee's immediate supervisor setting forth the nature of the grievance, the surrounding circumstances and the remedy sought. The immediate supervisor shall arrange a meeting within seven days of the receipt of the grievance at which the employee, a Union Steward designated by the Union Local, if the Union Local so requests, the Dean of the Division and the immediate supervisor shall attend and discuss the grievance. The immediate supervisor and Dean will give the grievor and the Union Steward their decision, in writing, within seven days following the meeting. If the grievor is not satisfied with the decision of the 3 immediate supervisor and Dean, the grievor shall present the grievance in writing at Step Two within 15 days of the day the grievor received such decision. Step Two The grievor shall present the grievance to the College President. The College President or the President's designee shall convene a meeting concerning the grievance, at which the grievor shall have an opportunity to be present, within 20 days of the presentation, and shall give the grievor and a Union Steward designated by the Union Local the President's decision in writing within 15 days following the meeting. In addition to the Union Steward, a representative designated by the Union Local shall be present at the meeting if requested by the employee, the Union Local or the College. The College President or the President's designee may have such persons or counsel attend as the College President or the President's designee deems necessary. In the event that any difference arising from the interpretation, application, administration or alleged contravention of this Agreement has not been satisfactorily settled under the foregoing Grievance Procedure, the matter shall then, by notice in writing given to the other party within 15 days of the date of receipt by the grievor of the decision of the College official at Step Two, be referred to arbitration. 32.04 A Any matter so referred to arbitration, including any question as to whether a matter is arbitrable, shall be heard by a Board of three arbitrators composed of an arbitrator appointed by each of the College and the Union and a third arbitrator who shall be Chair. 32.04 D The arbitration board shall not be authorized to alter, modify or amend any part of the terms of this Agreement not to make any decision inconsistent therewith; nor to deal with any matter that is not a proper matter for grievance under this Agreement. General 32.05 A If the grievor fails to act within the time limits set out at any Complaint or Grievance Step, the grievance will be considered abandoned. 4 32.05 B If an official fails to reply to a grievance within the time limits set out at any Complaint or Grievance Step, the grievor may submit the grievance to the next Step of the grievance procedure. 32.05 C At any Complaint or Grievance Step of the grievance procedure, the time limits imposed upon either party may be extended by mutual agreement. Ironically, these four grievances were initially referred to arbitration by OPSEU head office in error on March 14th, prior to either a Step 1 o__r a Step 2 meeting having been held with the College. The College strenuously objected to that in the following letter to the Council of Regents' co-ordinating officer (copied at the local level to Ron Martin, Local 244's Chief Steward): Sheridan College is in receipt of Lester Yearwood's correspondence dated March 14, 1996 in which OPSEU is referring the above captioned grievances to arbitration. By way of this letter, I am advising you that the College is in disagreement with this referral. The grievances were submitted to Human Resources on March 3, 1996 and an acknowledgement was provided to Local 244 on March 11, 1996 (see attached). A Step Two meeting regarding these grievances is scheduled for March 20, 1996. As these grievances have not yet been processed through the internal step procedure and the College has not received a referral to arbitration by the union local, I am requesting that the Counsel of Regents not arrange a hearing date at this time. Mr. Martin immediately advised head office to cancel the referral, at the same time issuing a strong rebuke in the following terms: 5 Dear Brother Lester: Re: Grievances of Sibbick, Norm LOCAL 244 Layoff; Transfer of Various Articles; Grievances (2) dated 96/03/03 Kindly read our grievances in the future. We are merely keeping you posted on what progress we are making, as there have been problems in the past with the Hamilton Office keeping track of our grievances. We will let you know when we have finished the second step on this grievance, at which time it can be properly posted for arbitration. In solidarity "Ron Martin" Ron Martin Chief Steward, Local 244 Sheridan College LM cc Damian Borrelli, Executive Director, Human Resources Ron Davidson, Grievance Department, OPSEU H.O. P.S. We have also been copying you on approximately 50 layoff grievances which have passed Step 1, but have not reached Step 2. DO NOT SET THESE FOR ARBITP~ATION until we have advised you that Step 2 has been completed and the College has refused to back off their positions. As noted, the parties did subsequently come to discuss these grievances in a meeting on March 2Otb, and given the divergence of their views, at that time agreed that that meeting would serve as both the Step 1 and Step 2 meeting. The deadline for a Reply by the College according to the collective agreement would thus have been April the 4th. On March 27th, well ahead of that, the College's Human Resources Department was working on the drafting of a reply through Susan Bawden, a Labour Relations Assistant whose responsibility it is to co-ordinate the grievance and arbitration process for the College. That work in fact continued beyond normal office hours, and by 6:15 p.m. the reply was ready for Mr. Borrelli's signature. The Human Resources Department is located on the second floor of the College building, and the Union office on the ground floor under it. Mr. Borrelli was preparing to attend a meeting of the Board of Governors at the College that evening, and as the Local President, Norm Sibbick, sits on the Board and had been seen by Ms. Bawden at the College earlier that day, Ms. Bawden thought that Mr. Sibbick might be still present in the Union office as well. A colleague in the Benefits side of Human Resources, Lynn Barrett, was just getting ready to leave, and as the way out to the parking lot requires one to pass by the office of the Union, Ms. Bawden asked Ms. Barrett if she would drop the envelope off to Mr. Sibbick on the way out. Given the hour, Ms. Barrett had the forethought to ask Ms. Barrett what she wanted her to do if the Union office were closed, and Ms. Bawden advised her in that event to slip the envelope under the door. When Ms. Barrett got to the Union office, it was closed and dark, and Ms. Barrett slid the envelope under the door as instructed. The next morning Ms. Bawden inquired of Ms. Barrett whether in fact she had slipped the envelope under the door, or had been able to deliver it to someone in person. Ms. Barrett indicated that she had had to slip it under the door. Notwithstanding that response, Ms. Bawden made no call to the Union office thereafter to confirm that the document was actually received. It was the evidence of Ms. Bawden that the parties had been in the habit of slipping "correspondence" under each other's door after closing hours from time to time, but that she had specifically asked the question of Ms. Barrett on this particular occasion "because it was a very important matter" Lin Martin, the Local office's secretary, testified that the College does from time to time leave less critical items under the door after closing, but never, in her experience, something as time-sensitive as a grievance document. She testified that the latter would be a very unwise thing to do, unless perhaps it were the final day to respond, because the office is small and sOmewhat cluttered by stacks of old-file boxes. Ms. Martin added that cleaning staff come in at night, and that a number of executive officers have keys as well. Ms. Martin noted that there has in the past been at least one piece of old correspondence that she recalls being discovered under a desk, having been kicked there accidentally by someone entering the office to turn the lights on. Ron Martin (no relation) testified that over his many years in office, this is the first time he can recall the College delivering a Step 2 reply under the door, although Mr. Martin at the same time concedes that other types of correspondence have been left that way, and that he himself has delivered grievance referrals to the College President under the door on occasion, after five o'clock. It was the evidence of Damian Borrelli that, upon his arrival at the College as Executive Director of Human Resources in May of 1994, it was his intention to clean up the number of 8 grievances sitting in limbo, and from a procedural point of view to run a tighter ship. That more rigid stance by Mr. Borrelli is not really disputed, and in fact was the subject of comment by the former Union President, Jack Urowitz, in the Union's newsletter of September 1994. In 1996 Mr. Martin himself wrote to his members, as the lay-off grievances were piling up, as follows: DATE: March 11, 1996 If you asked your supervisor or a college official for a discussion of why you were selected for layoff and that discussion did not take place during a period of four calendar days from the date of your layoff (time period extended from three days to four days by mutual consent between the College and Local 244), then you should complain (verbally) to your supervisor that the College has violated the provisions of 27.05(vii) which states the time frame within which the meeting must be held. Ask that your notice of layoff be withdrawn because of the violation of the contract. Your supervisor must reply within seven days. If the reply is negative, follow the same steps and time lines as were given in the generic grievance response to your layoff notice. Some persons who are on the layoff list appear to have been informally told by their supervisor that they must have part of their vacation during the layoff notice period. There are any number of precedents which state this is not appropriate. If you are officially notified, or even suspect you have been notified, complain verbally to your supervisor that this is not appropriate and that you want your vacation to follow the conclusion of the layoff notice period. If you receive a negative response or no response within seven days, commence the grievance procedure as outlined below. The Joint Employment Stability Committee is discussing the "retraining" situation in the contract. As soon as we have made a joint determination of appropriate procedures concerning retraining, we will issue another bulletin. 9 TRACKING GRIEVANCE TIME LIMITS: While we will keep copies of all your grievance responses and your grievances, we must ask that YOU TRACK YOUR OWN TIME LIMIT SITUATION - REMEMBER - the college and their lawyers will attempt to disqualify you on technicalities. This may be unpleasant, but they do this. Notwithstanding that background, however, it was obvious that there was an "unprecedented" volume of grievances being generated by the large-scale lay-off, and to maintain continuity Mr. Borrelli was trying to sit as the President's designee at Step 2 on all of them -- both individual and Union alike. The Union recognized that, and was prepared to allow some latitude in the time-lines for meetings, so long as the member whose grievance it was was agreeable in that regard as well. Lin Martin testified, however, that, in spite of Mr. Martin's memo to the faculty, she herself had a system for bringing forward the time-lines on individual grievances, so that she could call each member at the appropriate time and remind them. For the "Union" grievances, Norm Sibbick, the President, testified, there was not the same anxiety over meetings taking place and replies being received in a strictly timely fashion; they knew that Mr. Borrelli was being deluged, and the greater concern of the Union was to have their objections considered by the College, and responded to in a comprehensive fashion. Thus, while, as Ms. Martin testified, she would have noted in the files the date of receipt of the Step 2 replies on the initial four Union grievances on March 27th (the date of "delivery") had those replies indeed come to her at that time, the fact is that neither she nor Mr. Martin nor Mr. Sibbick 10 (nor anyone else in the Union to their knowledge) actually saw those replies until April 24th. Mr. Martin had himself been out of province for that intervening period, and Mr. Sibbick was content to wait a period for a considered reply from Mr. Borrelli as indicated. Thus the Union did not press the matter, until Mr. Martin and Mr. Sibbick on Mr. Martin's return discussed the grievance situation, and a call was put in to Sue Bawden reminding her that the replies were still outstanding. At that point Ms. Bawden advised Mr. Martin that the replies had already been delivered, and Mr. Martin said that she had better send him another copy. Ms. Bawden did that, and from there the parties join issue on the arbitrability matter that has been raised before us. The first question the board has to decide is: did the Union "receive" the Step 2 Reply on the initial four grievances on March 27th, within the meaning of Article 32.03 of the collective agreement? The Union does not challenge the statements of the College representatives w~en they say that the Reply was passed under the door after working hours that day. On the other hand, notwithstanding the lengthy evidence in the case, the College in the end does not argue that the Union representatives are being untruthful when they say that they did not in fact get it. The time line is specified to run from the date of "receipt by the grievor of the decision of the College official" Here the "grievor" is the Local Union. But the "Local Union" can only act through its representatives. We find that none of those 11 representatives actually received the Reply until April 24th, 1996. Mr. Hamilton argues that the Reply should be taken to have been received, however, based on the fact, as he put it, that it was delivered to the Union office "in the normal course" There is, of course, no "deemed" or "prima facie" rule of law, statutory or otherwise, that establishes receipt by the delivery of something under a door, after office hours. A party who elects to do that is putting itself, at the very least, at the mercy of the night cleaning staff, and in our view, if only for the purposes of the issue here, chooses to act at his or her own risk. And that really ties in to Mr. Hamilton's secondary argument, which is that even if the Union is found not to have received the Reply by April 24th, by virtue of Article 32.05 B the Union was expressly entitled to proceed to arbitration on its own, and the failure to do so within 15 days (of April 4th) constitutes abandonment under Article 32.05 A in any event. See Fanshawe College (Begert), decision of arbitrator Brent dated September 4th, 1992; Fanshawe College (Dobos), decision of arbitrator Swan dated November 26, 1991; Cambrian College (Bailey), decision of arbitrator Swan dated October 18, 1994; and St. Clair College (Murray), decision of arbitrator O'Shea dated March 8th, 1982. Those two articles once again read: 32.05 A If the grievor fails to act within the time limits set out at any Complaint or Grievance Step, the grievance will be considered abandoned. 12 32.05 B If an official fails to reply to a grievance within the time limits set out at any Complaint or Grievance Step, the grievor may submit the grievance to the next Step of the grievance procedure. We note, to begin with, that Article 32.05 B, applying in the face of defaulting behaviour on the part of the other party, simply says that a grievor "may" in that event proceed to the next step. Whereas, Article 32.05 A, dealing with a grievor's own inaction, states that the grievance "will be considered abandoned". Thus on the language alone we have considerable difficulty with the employer's argument: that a default on its part requires the other party to track the time lines exactly (in terms of when the other party should have acted) and to proceed on its own, against strict consequences, based on the other party's time lines. Some of the cases cited by the College are only marginally on point, and in the Cambrian Colleqe case, we note that the delay was one of some 2 1/2 years, in filing a grievance. "Abandonment" could therefore be supported in that case on other grounds. More importantly, the College's principal case in point, Fanshawe (Beqert), was in fact overturned on review: OPSEU v. Fanshawe College (1994), 68 O.A.C. 386. At page 389 Adams J. stated for the Court: [8] It is clear that in the letter dated October 6, 1988, the respondent College took the position that the grievance procedure set out in article 11 did not apply although offering the grievor the services of the Human Resources staff and a meeting, if she so desired. Moreover, not only did the College disclaim the application of article 11, by its own conduct, the College did not abide by its requirements. Then, on October 31, 1988, the College wrote to the grievor taking the position that article 11 did apply and that the mandatory time limits set out therein had expired. 13 Accordingly, the grievance was now deemed by the College to have been abandoned. A majority of the Board of Arbitration endorsed these entirely inconsistent positions of the respondent, holding that an unexplained time limit of 20 days, and for some reason running from October 6, 1988, had expired. The Board observed it was without statutory authority to relieve against the deemed abandonment provided for by the agreement. [9] We are all of the view an employer cannot take the position that a grievance procedure containing mandatory time limits does not apply and then assert those same time limits after their expiration, without prior notice to the grievor and the Union that this will be its position. Unfortunately, the majority decision failed to recognize this most basic and fundamental principle of fairness and, thereby, rendered a patently unreasonable result. We emphasize the College did not itself comply with the provisions of the grievance procedure but, nevertheless, sought to impose the time limits contained therein on the grievor without notice. This was patently unreasonable, if not unconscionable, conduct by the College and a decision of a board of arbitration insensitive to such conduct is itself patently unreasonable as a matter of law. The decision is therefore quashed. While, as Mr. Hamilton notes, the facts in that case are distinguishable from the present case, it seems to us that the principle is not. And that is, that a party cannot, without more, rely on its own default to trigger an obligation on the other party to then proceed in a "timely" way, measured from the point of the default. Compare also Alqonquin College (Graham) a decision of arbitrator Weatherill dated August 16th, 1982; and Georqian College (Union Grievance), a decision of arbitrator Teplitsky dated November 13th, 1990, wherein he stated, at page 3: In my opinion, the employer cannot rely on the Union's failure when its own breach of the Collective Agreement caused or contributed to this failure. 14 It may be that, in light of the "practice" of even grievance documents on occasion being delivered in this fashion before (in terms of specific evidence, by Mr. Martin at least), a party electing to do that at Sheridan might be relieved from the consequences of any alleged default on its own part flowing out of that; but that, in our view, is categorically different from a party attempting, on the basis of its own default, to visit strict consequences on the other party. In the circumstances here, for the College's "preliminary objection" to succeed, the evidence must point compellingly to actual receipt by Union officials of the Reply in question, and we find that it does not. The timeliness objection with respect to the initial four grievances is therefore dismissed. The "procedural" objection against the hearing of the fifth Union grievance we find to be even more bereft of merit. That grievance was dated April 2nd, 1996, and received by the College on April 4th. By April 24th, the Union had the Step 2 Reply to the first four grievances, as discussed above, and in their haste to then get things moving, they referred all five of the Union grievances relating to these layoffs to arbitration at once. The College responded with an objection that for this fifth grievance, no meeting had yet taken place. That was part of an April 30th memorandum from Mr. Borrelli to Mr. Sibbick setting out the College's preliminary objections, and stated: In addition, a fifth grievance, dated April 2, 1996 (96AC69), was attached to your correspondence. This grievance has been tentatively scheduled for a Step Two meeting on Monday May 6th at 11:00 a.m. As this 15 grievance has not yet been processed through the internal Step procedure, the College disagrees with the referral of this grievance to arbitration. Please confirm the availability of a union local representative for this meeting with Susan Bawden at extension 2222. The parties did, in accordance with that, proceed to a meeting on that grievance, although for scheduling reasons they agreed to delay it to May 16th. No mention was made at the meeting of the College's "objection" (that there had been no meeting), but rather, following an unproductive debate about the merits, it was agreed to schedule the fifth grievance for hearing before the same arbitrator, and on the same dates, as had been selected to hear the other four. That suggestion was reflected in a scheduling memo from Sue Bawden to Norm Sibbick which stated as follows (96C671 being the number assigned by the College to this fifth grievance): MEMO TO: Norm Sibbick President, OPSEU Local 244 copy: Lin Martin FROM: Susan Bawden Human Resources DATE: May 24, 1996 RE: CONFIRMED ARBITRATION SCHEDULE The College is now in receipt of the Confirmed Arbitration Schedule for the period September 9, 1996 to October 31, 1996. The following are the dates, arbitrations and arbitrators associated with these cases. September 11, 1996 Union Local grievances -96C282 Mitchnick -96C283 and 16 September 25, 1996 Union Local grievances -96C671 Mitchnick -96C672 -96C673 Please note that Management representatives were not available on October 17, 1996 which was the tentative date provided for the L. Drozdowski arbitration. Norm, we discussed the opportunity to have all five of the above Union Local grievances heard on one day rather than two. In light of the fact that the arbitrator is the same for both dates, would you please advise me of the Union's agreement to have these grievances combined at one hearing. Agreement on that was then confirmed in a handwritten memo from the Council of Regents to OPSEU dated August 20th, 1996 as follows: Re: Sheridan College Sept. 11 & 25 - 5 cases in total (96C282, 96C283, 96C671, 96C672 & 96C673) The Local Union and College Management have agreed to consolidate cases and hear all 5 together, but - over the 2 days (Sept. 11 & 25) as they are in front of the same arbitrator ... It is agreed that there has been no formal "re-referral" of the grievance to arbitration by the Union subsequent to the May 16th meeting, nor any further reference by the College, either orally or in any of the scheduling documents, to its "objection" about a meeting. In our view, where there has been an unequivocal referral of the grievance to arbitration, an objection by the College that no meeting has yet occurred on it, a meeting on it, and then an agreement that the matter would then be scheduled for arbitration along with the others, it would take a clear indication on the 17 part of the College to establish that its earlier "objection" was still considered alive. The College did not re-iterate such objection until a letter from counsel just prior to the hearing - - we suspect for the same reason we would find such objection to be without merit if they had: their objection had been simply the prematurity of going to arbitration without the opportunity for a meeting, and the parties then had their meeting, and scheduled the matter for arbitration. In our view there is nothing in the collective agreement that would mandatorily preclude the parties from proceeding in that fashion. Any way one looks at it therefore (i.e., whether as a "waiver" or on the "merits"), this second preliminary objection on the part of the College is dismissed. There are other preliminary objections by the College, which now must be scheduled for hearing. The only other issue before the board for decision at this point is that of "costs", for the adjourned first day of hearing in this matter, on September llth, 1996. The College and its counsel attended at the scheduled hearing in Oakville that day, as did the board. Unfortunately, that was 4 or 5 days into a strike against OPSEU by its staff, and when counsel for OPSEU arrived at the hearing site, he encountered a picket-line. Counsel advised the board that he was declining to cross the picket-line. That meant that OPSEU, unknown to it, and notwithstanding its retention of counsel, was not being represented at the hearing, and over the objection of 18 the College, the chair felt obliged to adjourn the matter, the College now wants its costs against OPSEU. Article 32.04 E provides: 32.04 E The College and the Union shall each pay one- half the remuneration and expenses of the Chair of the arbitration board and shall each pay the remuneration and expenses of the person it appoints as arbitrator. These are, the College submits however, special circumstances, and the College points to some cases that would support a departure from the norm on the question of wasted costs where, as here it submits, the situation was within the control of the defaulting party: Hawker Siddely (1989), 7 L.A.C. (4th) 172; Cambrian College (Seleck¥), decision of arbitrator McLaren dated April 30th, 1993; and at least by way of obiter, E & L Caterinq (1992), 27 L.A.C. (4th) 129 (Solomatenko). We have difficulty with the submission that the situation here was "within OPSEU's control". OPSEU, as employers are allowed to do, made the decision to attempt to continue to operate during a strike. To that end it retained outside counsel in this case to represent it at the hearing, and ensure that it could maintain "business as usual". This particular hearing arose early in the strike, however, and was outside Toronto, and it was not obvious that there would be a picket-line to contend with. There was, therefore, no discussion on the issue between OPSEU and its counsel prior to the event. When counsel did in fact encounter a picket-line, he elected not to cross. Because of the timing and lack of normal staffing at the OPSEU office, counsel was not able to "discuss" that question with the client, 19 OPSEU. OPSEU, therefore, had no knowledge that it was being unrepresented at the hearing, and no opportunity to consider what measures it might take to ensure, as it believed it had already accomplished, that the hearing would proceed as scheduled. In the circumstances, therefore, we do not see the last-minute "unavailability" of OPSEU's counsel, uncommunicated to OPSEU, as grounds for exercising an extraordinary jurisdiction (assuming such exists) for an after-the-fact award of costs. The College's request for indemnification is accordingly denied. The matter will continue, on dates to be set. Dated at Toronto this 2nd day of January, 1997 M. G. Mitchnick I concur "M. Sullivan" M. Sullivan I dissent (see attached) "J. Campbell" J. Campbell DISSENT I regret that I find it necessary to dissent from the majority award in this matter. In particular, I cannot concur with the findings with respect to when the Union received the Step 2 Reply within the meaning of Articte 32.03 of the collective agreement. The evidence before the Board clearly indicated that both parties had from time to time delivered correspondence by slipping material under the office door after working hours and it was an accepted method of delivery. Also, the Union did not challenge the evidence from College representatives that the response to the grievance was slipped under the door of the Union office on March 27. Surely, it was incumbent on the receiving party to organize its office in such a way to ensure that deliveries were not misplaced. Given the practice of the parties and the uncontradicted evidence of the College representatives, I would have found that the Union did indeed receive the College's response to the grievances on March 27 and the time constraints with respect to the next step started on on that date. With respect to the comments regarding Article 32.05 B, and the use of the words "may submit the grievance to the next Step of the grievance procedure", I believe it only reasonable to infer from the collective agreement language that a grievor also "may not" proceed to the next step. Surely if it was the intention to proceed to the next step, then that process should have been intitiated within the prescribed time limits. ~Iacqu~line G. Campbell December 10,1996 Employer Nominee