HomeMy WebLinkAboutUnion 98-07-27 q B 500-
IN THE MAWR OF AN ARBIT~TION ~53~ -
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O~TA~IO ~UBklC S~VIC~S ~M~kOY~S' U~IO~
GRIEVANCES RE VACATION ENTITLEMENT
BOARD OF ARBITRATION:
JANE H. DEVLIN CHAIR
JACQUELINE G. CAMPBELL COLLEGE NOMINEE
MICHAEL J. SULLIVAN UNION NOMINEE
BARRY J. BROWN, FOR THE COLLEGE
GAVIN LEEB, FOR THE UNION
OPSEU FII E NOS.' 98B517 98B526 98B533
988520 98B527 988534
988521 988528 988535
988522 98B529 988536
98B523 98B531 98B$37
98B524 988532 98B538
988525
HEARING DATE: MAY 14, 1999
This matter concems a Union grievance and a number of individual
grievances which allege that in calculating vacation entitlement, the College has
improperly failed to give credit for prior part-time service outside the bargaining
unit.
The relevant provisions of the 1992194 support staff collective
agreement which remained in effect when the grievances were filed are as
follows:
1. RECOGNITION
1.t Exclusive Bargaining Agent
The Union is recognized as the exclusive bargaining agent for all Support
Staff employees of the Colleges, save and except:
persons regularly employed for twenty-four (24) hours per week or
less and persons employed temporarily during the College vacation
periods;
11. VACATION
11 .1 Entitlement
Effective June 30, 1991, employees on the active payroll of the College
who have completed the years of continuous service, as of June 30th, shall
be granted vacation with pay as follows:
1 - 6 years: 15 working days
7 years: 17 working days
6 years: 16 working days
9 years: 20 working days
10 years: 20 working days
2
11 years: 21 working days
12 years: 22 working days
13 years: 23 working days
14 years: 24 working days
1.5 years: 25 working days
16 years: 26 working days
17 years: 26 working days
18 years: 26 working days
19 years: 27 working days
20 years: 27 working days
21 years: 28 working days
22 years: 28 working days
25 years: 29 working days
24 years: 29 working days
25 or more: 30 working days
11.2 Calculation of Continuous Service
In determining the period of continuous service of employees on the active
payroll for the purpose of vacation entitlement:
an employee's previous uninterrupted service with the College
immediately prior to and consecutive with its establishment as a
College of Applied Arts and Technology shall be included;
an employee who, for any reason, has less than twelve (12) full
months of active employment during the one (1) year period
immediately prior to June 30, in any year, shall receive a lesser
vacation with pay on a pro rata basis under the schedule of vacation
set out in this Article, subject to any accumulation of service under
Article 14.2.
Active employment means actual attendance at the work place and the
performance of work, but includes absence from work for vacations and
holidays, or illness for up to six (6) months, or during pregnancy or parental
leave or development leave.
14. JOB SECURITY
14.2 Accumulating Seniority
Seniority and service shall accumulate for all purposes under the Collective
Agreement for a pedod of up to, but not to exceed, six (6) calendar months
during the term of this Agreement during any leave(s) of absence granted,
with or without pay, pursuant to the provisions of this Agreement.
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· ' Notwithstanding the foregoing, seniority and service shall accumulate for
up to thirty-five (35) weeks in the case of combined pregnancy and parental
leave, and during the length of developmental leave and during the first
twelve (12) months of absence on Workers' Compensation and for any
period of layoff pursuant to the Less Than 12 Month Positions Letter of
Agreement. This provision shall not apply in the case of probationary
employees who shall be required to complete six (6) months of active
employment to attain seniority unless waived by the College. It is
understood that seniority and service do not accumulate during periods of
layoff under Artide 15.
14.3 Transfer Into Union
A person employed by the College, who is transferred into the bargaining
unit, will be accorded full seniority, upon completion of the probationary
period, based on length of service, Part-time support staff employees
transferred into the bargaining unit, after November 14, 1991, shall have
their seniority prorated, upon completion of their probationary period,
based on a proration of hours of the part time position to the hours of the
full-time position using 1820 hours per year as constituting the hours of the
full-time position.
It is understood, however, that for the purposes of the application of Article
15.4, supervisory personnel and employees in the academic staff
bargaining unit, who are transferred into the bargaining unit shall be entitled
to exercise only that portion of their seniority, if any, accumulated as an
employee in the bargaining unit or what formerly was the bargaining unit.
14.5 Proration of Part-Time Service for Probation
Where a part-time employee is hired by the College into a full-time position
in the bargaining unit, which is either the same position or, is sufficiently
similar in nature, he/she shall be credited with service towards completion
of the probationary period, based on a proration of the hours of the part-
time position to the hours of the full-time position using 1820 hours per year
as constituting the hours of the full-time position, to a maximum period of
credit of three (3) months service towards the completion of the
probationary period, and provided such service occurred within one (1)
year of the date of hiring into the bargaining unit.
(,-.,! 4
APPENDIX B
INCLUSION PROCEDURES
The following conditions are applicable to persons who are employed by a
College of Applied Arts and Technology (hereinafter called "the College") in
positions designated as Administrative Staff or otherwise excluded from the
Support Staff Bargaining Unit and who are found to be bargaining unit
employees as a result of specific decisions of the Ontario Labour Relations
Board or by agreement of the Council/College and the Union:
6. Vacation
(a) Employees will retain vacation entitlement earned as Administrative
Staff or an otherwise exduded employee for the vacation year in
which the date of indusion occurs and one (1) additional vacation
year and vacation pay shall be in accordance with Articles 11.2, 11.3
and 11.4.
("~, (b) Effective June 30th of the vacation year thereafter and of each
subsequent vacation year, there will be a reduction in vacation
entitlement of one (1) day until such vacation entitlement coinddes
with entitlement under the effective Collective Agreement for CAAT
Support Staff and vacation pay shall be in accordance with Artides
11.2, 11.3 and 11.4.
(c) For the purpose of calculating an employee's vacation entitlement
under Article 11, it is agreed that the employee will receive credit for
one hundred per cent (100%) of his/her continuous service in the
College.
7. Basic Life Insurance, Extended Health Insurance, Dental
Insurance, Supplemental Life Insurance, Dependent Life
Insurance, Short Term Disability Plan, Long Term Disability
Insurance, Vision and Hearing Care Plans.
These Support Staff Plans are effective the first day of the third
calendar month following the date of inclusion.
9. Union Dues
Union dues deductions will commence from the date of inclusion.
It was the submission of the Union that the language of Article 11 .I
of the collective agreement is clear and unambiguous and specifies that vacation
entitlement is based on years of continuous service. The Union maintained that
such service includes service as a part-time employee and, in support of this
submission, relied on Georgial~ College of Applied Arts and T~chnoloaj~y ~
Ontario Public Service EmDIovees Union (1997), 59 L.A.C.(4th) 129 (Schiff).
It was the submission of the College that under Article 11, continuous
service for purposes of vacation entitlement is limited to service within the
('"""hbargaining unit. Moreover, in the event that the Board were to find the collective
agreement to be ambiguous, the College submitted that we ought to consider
extrinsic evidence as an aid to interpretation. In the alternative, the College
contended that the Union is estopped from claiming that continuous service
includes part-time service outside the bargaining unit. By way of reply to these
latter submissions, the Union submitted that the College failed to establish a
proper basis for the use of extrinsic evidence, either as an aid to interpretation or
in support of the application of the doctrine of estoppel.
Before setting out the extrinsic evidence tendered by the College,
which took the form of past practice and negotiating history, it should be noted
that there are two prior awards dealing with the calculation of seniority under the
f-
support staff collective agreement. The first of these is an award of a Board
chaired by Arbitrator Palmer in C..,~)13{~St0ga College of Aoolied Arts and
Technoloav and the Ontario Public Service Fmolovees Union, January 10, 1986
(unreported). At the time of that award, Article 14.3 of the collective agreement
provided as follows:
14.3 Transfer into Union
A person employed by the College, who is transferred into the bargaining
unit, will be accorded full seniority based on length of service. It is
understood, however, that for the purposes of the application of Article
15.4, supervisory personnel and employees in the academic staff
bargaining unit, who are transferred into the bargaining unit shall be entitled
to exercise only that portion of their seniority, if any, accumulated as an
employee in the bargaining unit or what formedy was the bargaining unit.
Based on that provision, the Board determined that employees transferred into
the bargaining unit were entitled to "full seniority" based on length of service,
which included part-time service outside the bargaining unit.
The same issue subsequently arose before a Board which included
the present Chair in Mohawk College of Applied Arts and Technology and Ontario
Public Service Emolovees Union, March 30, 1990 (unreported). Although the
collective agreement had been amended subsequent to the Conestoaa Colleoe
award to include Article 14.5 which provided credit, in some cases, for part-time
service toward completion of the probationary period, the Board concluded that
the issue turned on the interpretation of Article 14.3, to which no amendment had
been made. Based on the language of that provision and the earlier Gonostoaa
¢olleae award, the majority of the Board found that employees transferred into
the bargaining unit were entitled to full seniority based on length of service, which
included part-time service.
As to the evidence introduced in this case, Rosalie Spargo, a Labour
Relations Specialist with the College, testified that for purposes of vacation
entitlement, the College has never given credit for part-time service. Instead,
service has always been calculated from the date the employee enters the
bargaining unit. Ms. Spargo also testified that the College has a system of
notifying employees of their vacation entitlement and, by way of example, she
identified a memorandum dated February 23, 1996, which was forwarded to each
employee setting out the current balance of his or her vacation entitlement, any
new entitlement as of July 1, 1996 as well as any vacation days previously
advanced. Ms. Spargo testified that similar memoranda have been forwarded to
employees annually since prior to the time she joined the staff of the College in
1989.
Ms. Spargo also testified that toward the end of 1995, it became
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apparent that there would be a restructuring at the College which would result in
'-'- significant displacement of employees. As a result, the members of the Union
College Committee, which included Ms. Spar§o and Jay Jackson, the President
of both the local and provincial bargaining units, derided that steps should be
taken to ensure that the seniority of all employees was property calculated.
Accordingly, in early February, 1996, a memorandum was forwarded to each
member of the bargaining unit setting out his or her established seniority date
and offering the employee an opportunity to provide further information to the
College if he or she considered the date spedfied to be inaccurate. Attached to
the memorandum were various provisions of the collective agreement, including
Artides 14.2 and 14.3. Ms. Spargo testified that during this process, no
employee requested any adjustment to his or her vacation entitlement based on
service as a part-time employee.
Among the employees to whom the memorandum of February, 1996
was forwarded were Susanna Mesich and Norma Pennington-Drabble. Both of
these employees had worked for some period as part-time employees prior to
their transfer into the bargaining unit. Letters forwarded to these employees at
the time of their transfer (Ms. Mesich having been transferred into the bargaining
unit in September, 1979 and Ms. Pennington-Drabble in November, 1985), made
no explicit reference to vacation entitlement but indicated that the terms and
conditions of employment were governed by the provisions of the collective
agreement. Thereafter, by memoranda dated September, 1993 and May, 1994,
the Union advised the College that both Ms. Mesich and Ms. Pennington-Drabble
would be serving as Union Stewards.
The evidence also indicates that in late 1995, Ms. Mesich and Ms.
Pennington-Drabble contacted the Human Resources Department to inquire
about an adjustment to their seniority dates in view of the fact that they had
worked on a part-time basis prior to their transfer into the bargaining unit.
Although in response to these inquiries, the seniority dates of both employees
were adjusted by a number of months, Ms. Spargo testified that neither employee
requested any adjustment to her vacation entitlement.
In fact, according to Ms. Spargo, although from time to time, the
Union raised issues with respect to matters such as vacation scheduling, no issue
was raised regarding credit for part-time service for purposes of vacation
entitlement until a Union Management Committee meeting in February, 1997,
following the issuance of the Georaian College_ award. Inthat award, which was
also decided under the 1992/94 collective agreement, the majority of the Board
found (1) that under Article 11 .1, continuous service, which forms the basis for
vacation entitlement, includes service as a part-time employee: (2) that with
respect to the College's submission that the language of the collective agreement
was ambiguous, one of the criteria for the use of extrinsic evidence as an aid to
interpretation had not been satisfied; and (3) that the College had failed to make
out a case for the application of the doctrine of estoppel. Based on the Georgian
Colleae award, the Union maintained at the meeting in early February, 1997, that
members of the bargaining unit ought to have their vacation entitlement adjusted
to take into account periods of part-time service. The College, however, refused
to accede to this request, as a result of which the present grievances were tiled.
Apart from evidence of past practice, the College also introduced
evidence of negotiating history. This evidence was given by Wallace Kenny, a
partner in the law firm of Hicks Morley Hamilton Stewart and Storie and the
spokesperson for the Council of Regents in bargaining with the Union for support
staff employees. Mr. Kenny testified that the issue of part-time service for
purposes of seniority was raised in negotiations for the 1991192 collective
agreement following the issuance of the Mohawk College award. According to
Mr. Kenny, that award was inconsistent with the Colleges' practice of calculating
seniority from the date of an employee's transfer into the bargaining unit. In this
regard, Mr. Kenny explained that the earlier (;;onestoga Colleae award (which
was relied upon by the majority of the Board in the Mohawk Colleae award) was
regarded as anomalous and had not caused any change in the Colleges' practice.
In any event, as a result of discussions during negotiations, the
parties agreed to amend Article 14.3 of the collective agreement such that
employees transferred from part-time to full-time positions prior to the date of
ratification (which was November 14, 1991) would have their seniority calculated
in accordance with the Mohawk College award. However, the seniority of
employees transferred subsequent to that date would be prorated based on the
number of hours of the part-time position compared to those of the full-time
position, which constituted 1820 hours per year. Mr. Kenny testified that there
was no discussion during negotiations for the 1991192 collective agreement or
during subsequent negotiations until those for the 1997/2000 collective
agreement regarding credit for part-time service for purposes of vacation
entitlement.
Ms. Kenny also testified that at the time of negotiations for the
1991/92 collective agreement, both parties were aware the Colleges did not give
credit for part-time service for any purpose and that had Union proposed that
credit be given for such service for purposes of vacation entitlement, the Council
of Regents would have resisted such a proposal. The Union, however, did not
raise the matter and it was not Mr. Kenny's impression that the Union's failure to
do so was attributable to an understanding on its part that the language of the
collective agreement was being properly applied. Finally, Mr. Kenny testified that
although some discussions took place between the parties at the time of expiry of
the 1992/94 collective agreement, the Social Contract Act was in effect and the
Union subsequently exercised its right under the Act to extend the terms of that
agreement.
Decision:
As provided in Article 11 of the collective agreement, vacation
entitlement for employees on the active payroll of the College is based on years
,,"-,,of continuous service. As noted previously, in the Georaian Colleae award, the
majority of the Board found that the term "continuous service" includes service as
a part-time employee outside the bargaining unit. The issue of continuous
service for purposes of vacation entitlement under Article 11 was also considered
in _¢on, estoga Colleae and OPSFU August 27, 1998 (Brent (unreported))
although, in that case, the Board did not find it necessary to come to any
conclusion regarding the proper interpretation of Article 11 .1 as the majority found
that the Union was estopped from claiming that continuous service included
service as a part-time employee.
In view of the Georaian Colle.qe award, it is apparent that the
meaning to be given to the term "continuous service" in Article 11 .I of the
13
collective agreement is not a matter of first impression for this Board of
Arbitration. In these circumstances, we are of the view that it would be
inappropriate to depart from the interpretation adopted in Georaian Colleae
unless we are convinced that the earlier award is clearly wrong. In fact, were it
otherwise, parties would be encouraged to re-arbitrate issues in the hope that a
differently constituted Board would adopt a different interpretation.
Nevertheless, the College contended that no deference should be
afforded to the Georoian Colleae award as that case was decided without regard
to the provisions of Appendix B to the collective agreement. This Appendix
specifies the terms and conditions of employment which are to apply to persons
occupying positions excluded from the bargaining unit which are subsequently
found to be properly induded in the unit. Paragraph 6(c) of the Appendix
provides that for purposes of calculating vacation entitlement under Article 11, the
employee is be credited with "100% of his/her continuous service with the
College". It was the submission of Mr. Brown, on behalf of the College, that if
"continuous service" in Artide 11.1 included service outside the bargaining unit,
there would be no need for paragraph 6(c).
In the Board's view, however, Appendix B would appear to constitute
a complete code with respect to the terms and conditions of employment
14
applicable to those occupying excluded positions which are subsequently found
to be included in the bargaining unit. Moreover, in paragraph 6, the parties have
agreed that for a specified period, such employees will retain the vacation earned
in excluded positions. In these circumstances, it is not surprising that they also
addressed the issue of service for purposes of vacation entitlement, particularly
as other provisions in Appendix B make reference to the date of inclusion. The
Board notes that paragraph 6(c) also refers to "continuous service" and, therefore,
contains precisely the same terminology which appears in Article 11 .1. In the
result, the Board is not persuaded that the provisions of Appendix B are sufficient
~,,.,%, to cause us to depart from the interpretation of Article 11.1 adopted in the
Georaian Colleg~ award. Moreover, although Mr. Brown submitted that the
majority of the Board in that case placed undue reliance on the Conestoaa
Colleae and Mohawk College_ awards, which dealt with seniority rather than
service, it is not uncommon for Boards of Arbitration to consider the manner in
which the parties have dealt with seniority when dealing with issues related to
service.
As to the College's alternate argument which is based on ambiguity,
in the Georaian Colleae award, the majority of the Board found that the first
criterion for the use of extrinsic evidence as an aid to interpretation had not been
satisfied as there was a clear preponderance in favour of one meaning when the
words were viewed in context: see Re John l~ertram & Sons Co. ltd. (1967), 18
L.A.C. 362 (Weiler). With respect to this issue as well, this Board is not prepared
to depart from the conclusion reached in the Georaian College award.
The final matter, therefore, concerns whether this is an appropriate
case for the application of the doctrine of estoppel. This doctrine applies where
one party, by its words or conduct, represents to the other that it does not intend
to rely on its strict rights under the agreement. Where the other party relies on
that representation to its detriment, the party that made the representation will not
be permitted to revert to its strict rights as if the representation had never been
made: Combe v. Combe [1951] 1 All E.R. 767 (C.A.) and Re Canadian National
Railwav Co. et al. and Beattv et al. (1981), 128 D.L.R.(3d) 236 (Ont. Div. Ct.).
There would appear to be no dispute that the representation relied on to support
an estoppel must be clear and unambiguous and there must be an intention to
affect legal relations between the parties. Such an intention, however, need not
be express but may be inferred from a course of conduct: see Owen Sound
Public Library Board v. Mial Developments Ltd. et al, (1979), 102 D.L.R.(3d)685
(Ont C.A.) and Travellers Indemnitv Co, of Canada v. Maracle (1991), 80
D.L.R.(4th) 652 (S.C.C.).
16
Although it has also been held that silence or inaction may constitute
the necessary representation, this is only the case where the representor owes a
legal duty to the other party to make a particular disdosure: see Scotsburn Co-
operative Services Ltd. v. W.T. Goodwin I rd, (1985), 16 D.L.R.(4th) 161 (S.C.C.)
and Georoian Colleae (_.supra). While in this latter award, it was suggested that a
union owes no legal duty to an employer to indicate whether or not it agrees with
the manner in which the collective agreement is being administered, other awards
have taken a somewhat different view: see Re Corooration of the City of
Penticton and Canadian Union of Public FmDIovees (1978), 18 LA.C.(2d) 307
(B.C.L.R.B.) and Conestooa College and OPSEU August 27, 1998 (supra). In the
former award, the Board commented as follows:
But a collective bargaining relationship is quite a different animal. The
union and the employer deal with each other for years and years through
successive agreements and renewals. They must deal with a wide variety
of problems arising on a day-to-day basis across the entire spectrum of
employment conditions in the workplace, and often under quite general and
ambiguous contract language. By and large, it is the employer which takes
the initiative in making operational decisions within the framework of the
collective agreement. If the Union leadership does not like certain
management actions, then it will object to them and will carry a grievance
forward about the matter. The other side of that coin is that if management
does take action, and the union offidals are fully aware of it, and no
objection is forthcoming, then the only reasonable inference the employer
can draw is that its position is acceptable. Suppose the employer commits
itself on that assumption. But the union later takes a second look and feels
that it might have a good argument under the collective agreement, and the
union now asks the arbitrator to enforce its strict legal rights for events that
have already occurred. It is apparent on its face that it would be
inequitable and unfair to permit such a sudden reversal to the detriment of
17
the other side. In the words of the Board in District of Bumaby, cited above
[at p. 103], "It is hard to imagine a better recipe for eroding the atmosphere
of trust and co-operation which is required for good labour management
relations, ultimately breeding industrial unrest in the relationship, all
contrary to the objectives of the Labour Code": see also the observations of
Mr. Justice Hutcheon in Larson et al. v. McMillan Bloedel (Albemi) Ltd.,
cited above at p. 764. To return to the metaphor which was used earlier, it
is equally unacceptable to watch someone go out on the end of the limb, as
it is to invite that person out on the limb - before sawing it off.
To avoid any misconception about that conclusion, let me immediately add
these two caveats. I am assuming in this analysis that responsible union
offidals are aware of what the employer in fact is doing. In my view, there
is no obligation on the part of the union to take affirmative action to find out
how the employer is actually administering the collective agreement- e.g.,
how it is applying different monetary provisions in the contract to produce a
final figure in the employees' pay-cheques: see Pilkington Bros. (Canada)
Ltd. and United Glass & Ceramic Workers, Local 295 (1966), 17 L.A.C. 146
(Arthurs) at p. 155. In this case, suppose the union officials had not been
aware that the employer had failed to put additional insurance coverage
into effect. The union would not have been estopped from enforcing its
contract position. When Sieg died, the union awakened to the problem,
and it advanced its arguments under the collective agreement. But in a
case such as this one, when the union does know how the employer has
interpreted and applied a contract provision, then it is under an obligation to
make its objections known within a reasonable period of time, in order to
alert the employer to the risks in its own course of action. In this case, the
union did not object. Then, for reasons stated above, if the employer can
show that it went ahead and acted in reliance on this acquiescence by the
union, the union is estopped from making its objection and pursuing its
grievance ex post facto.
VVhile the C.,itv of Penticton award suggests that an estoppel based on silence
requires actual knowledge of the employer's practice on the part of the union, as
pointed out by the College, other awards have suggested that it is sufficient if the
un.~on ought reasonably to have known of the practice: see, by way of example,
18
Re Board of Commissioners of Police for the Citv of Owen Sound and Owen
Sound Police Association (1984) 14 LA.C.(3d) 46 (M.G. Picher) and Re Domatas
Inc, and Aluminum. Brick & Glassworkers intemational Union. Local 2602 (1994),
40 L.A.C.(4th) 398.
In this case, Mr. Brown contended that, in fact, the Union was aware
that no credit was given for part-time service for purposes of vacation entitlement:
that the Union failed to object to this practice; and that the College and the
Council of Regents relied on the Union's silence to its detriment by failing to deal
with the matter in bargaining. It was the submission of Mr. Leeb, on behalf of the
Union, however, that the evidence failed to demonstrate that the Union was
aware of the practice in issue.
As to the evidence, it is clear that while the parties discussed part-
time service for purposes of seniority during negotiations for the 1991192
collective agreement, there was no discussion either during those negotiations or
subsequent negotiations prior to 1997 regarding part-time service for purposes of
vacation entitlement. Moreover, although Mr. Kenny's evidence indicates that at
the time of negotiations for the 1991192 collective agreement, the Council of
Regents was of the view that the Union was aware that the Colleges gave no
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credit for part-time service for purposes of vacation entitlement, no factual basis
was offered from which we could draw such a conclusion. In fact, Mr. Kenny
acknowledged that it was not his impression that the Union failed to raise the
issue as it understood that the language of the agreement was being properly
applied or, in other words, because it was unaware of the practice in question. In
these circumstances, therefore, the Board is not prepared to draw an adverse
inference from the Union's failure to call evidence in response to the evidence of
Mr. Kenny as, without more, the Council of Regents' belief regarding the Union's
knowledge of the practice is not sufficient to found an estoppel. In this regard, the
Board is of the view that caution must be exercised when silence is relied upon to
t,,,-,,,~ support an estoppel as estoppel effectively precludes a party from relying on its
strict rights under the collective agreement.
As to the knowledge of the local Union at Sheridan College, Mr.
Brown pointed out that both Ms. Mesich and Ms. Pennington-Drabble, who were
Union Stewards, had worked as part-time employees prior to their transfer into
the bargaining unit. Accordingly, they were aware that they did not receive credit
for this service for purposes of vacation entitlement. In late 1995, these
employees also requested an adjustment to their seniority to take into account
their part-time service but did not request any adjustment to their vacation
entitlement.
---,,,! 2o
Nevertheless, as pointed out by Mr. Leeb, there was no evidence to
indicate that either Ms. Mesich or Ms. Pennington-Drabble served as Union
stewards prior to the fall of 1993. Accordingly, there is no basis upon which we
could attribute knowledge of the College's practice to the local Union prior to that
time. Moreover, even if we were to find that the Union's silence or, in other
words, its failure to object to the College's practice subsequent to the fall of 1993
could be construed as a representation of its intention not to rely on its strict
rights under the collective agreement, by that point in time, negotiations for both
the 1991/92 and 1992194 collective agreements had been concluded. Although
[,,,.-,,, there were also some discussions between the parties at the time of expiry of the
1992/94 collective agreement, the Union exercised its right under the ~
Contract Act to extend that agreement. In these circumstances, therefore, it
cannot be said that the College lost the opportunity to deal with the matter in
bargaining. Accordingly, we find that the necessary detrimental reliance has not
been established and, therefore, a case for the application of the doctrine of
estoppel has not been made out. Finally, it should be noted that although we
have reached the same conclusion on this issue as the majority of the Board in
the Geo~ai~ln I e ge award, our finding is based entirely on the evidence
introduced in this case. Indeed, this Board does not subscribe to all of the
comments in the Georgian Colleoe award regarding the application of the
doctrine of estoppel.
Moreover, while a different conclusion regarding estoppel was
reached in Conestoaa Colleae and OPSEU August 27, 1998 (,~upr~), it is
apparent that the result also turned on the evidence introduced in that case.
Moreover, although in support of an estoppel, the majority of the Board relied on
discussions which took place between the parties in early 1996, the majority also
found that as early as 1989, a member of the local Union executive had direct
knowledge of the College's practice which did not involve credit for part-time
service for part-time service for purposes of vacation entitlement. The Union,
however, did not grieve the matter or raise it as an issue in central bargaining. As
a result, it was found that "the College reasonably took the Union's failure to act
at face value and did nothing to try to protect itself from any increased claims for
vacation entitlement". In this case, in contrast, there was no evidence that the
Union had knowledge of the College's practice until the fall of 1993 at which
point, the Council of Regents could not have effectively dealt with the matter in
bargaining. Accordingly, the necessary detrimental reliance has not been
established.
As to the matter of remedy, the Board was constituted under the
1992/94 collective agreement and, therefore, does not have jurisdiction to award
relief under earlier agreements: see, by way of example, J~ Goodvear Canada
Inc. and United Rubber Workers. Local 232 (1980), 28 L.A.C.(2d) 196 (M.G.
Picher); Re F,B~, rljstillery Co. ltd. and Brewery. Ma It & Soft rJdnk Workers,
local 304 (1987), 31 LA.C.(3d) 122 (H.D. Brown) and Re Northerrl College of
Al~plied Arts & ']'echr~lggy and Ofltario Public Service Employees Union (1992),
27 L.A.C.(4th) 98 (H.D. Brown). Moreover, although an estoppel has not been
made out, it is apparent that for some period subsequent to the fall of 1993, the
Union acquiesced in the College's practice. In these circumstances, therefore, it
was entitled to give notice to the College as it did in February, 1997 that it
intended to rely on its stdct dghts under the agreement. The present grievances
were subsequently tiled and, in the Board's view, in accordance with the
collective agreement, relief must flow from the time of the filing of the grievances.
In fact, daims to increased vacation entitlement prior thereto would appear to be
untimely. In the result, the Board remits the matter of remedy to the parties and
shall remain seized to deal with issue and for purposes of implementation of this
award.
DATED AT TORONTO, this 27th day of July, 1999.
Chair
"I dissent - Jacquel~ G. Camp]~ll"
College Nominee
"I conct/r -Mictmel J. Sullivan"
Union Nominee