HomeMy WebLinkAboutUnion 02-02-19IN THE MATTER OF AN ARBITRATION
BETWEEN: SAULT COLLEGE
AND ONTARIO PUBLIC SERVICE EMPLOYEES
UNION, LOCAL 612
AND IN THE MATTER OF A UNION GRIEVANCE
OPSEU FILE #00D365
BOARD OF ARBITRATION: MAUREEN K. SALTMAN, CHAIR
DAVID CAMELETTI, COLLEGE NOMINEE
EDWARD SEYMOUR, UNION NOMINEE
APPEARANCES:
FOR THE COLLEGE: DAVID W. BRADY
FOR THE UNION: GAVIN LEEB
AWARD
The issue in this case is whether a student hired on a full-time basis
to do office and clerical work during the summer vacation period ought to be
covered by the collective agreement.
The evidence indicates that in or around November or December,
1999, a Clerk General D in the Financial Aid Office was declared redundant. The
grievance arises because some time thereafter, in the summer of 2000, a student
was hired to work full-time in the same office. This student was hired pursuant to
a job posting under the Summer Work Program, which is one of the means by
which the College provides financial assistance to students. The Union claimed
that the student hired in the Financial Aid Office, who was paid the minimum
wage, was improperly denied coverage under the collective agreement. In the
event that its claim is upheld, the Union reserved the right to argue that the
student hired under the Summer Work Program performed the work of a Clerk
General D. However, it was agreed between the parties that the Board deal with
the first issue and remain seised with respect to the second.
With regard to the first issue, the Registrar of the College, Jim Erb,
testified that, as a result of tuition increases announced on November 30, 1995,
the Ministry of Education issued guidelines on May 13, 1996 requiring that 10%
of the additional tuition fee revenue collected from students be set aside and
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reserved for student financial assistance (referred to as "tuition fee set aside
funds"). Mr. Erb acknowledged, however, that there is nothing in the government
guidelines which mandates that tuition fee set aside funds be expended on
summer employment. In fact, a clarification issued on May 11, 1998 provides
that "[i]nstitutions should plan to disburse funds during the academic year, and
only funds which are residual at year end should be spent on summer
employment programs". Mr. Erb acknowledged that there was no direction of
any sort given as to the terms and conditions of summer employment.
Mr. Erb also testified that, although the hiring of summer students
varied from year to year depending on employment rates both in the province
and the local community (there being more students hired in years of high
unemployment), he could not recall a time in the past 20 or 30 years when
summer employment was not offered as a means of providing financial
assistance to students. In fact, proposals for the hiring of summer students
under the government-initiated Student Employment and Experience ("SEED")
Program, which has only recently ceased to exist, were always reviewed by the
Support Staff Union/College Committee. Nevertheless, Mr. Erb acknowledged
that concerns had been expressed that the hiring of students (although perhaps
not specifically summer students) was not being brought to the attention of the
Support Staff Union/College Committee. These concerns were expressed in the
Minutes of the Support Staff Union/College Committee Meeting dated August 21,
1996 as follows:
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9. OWSP (Ontario Work Study Pro.qram) and Other Pro.clrams
Allison stated that in the past, the SSU/C committee has reviewed
proposals for the SEED program only. There are a lot of other
programs (OWSP, NORTOP, SEND, etc.) coming through the
College at this time. The union feels that all of the programs should
be brought to the union/college committee. There is a concern
regarding the OWSP position and filing clerks in Financial Aid,
which will have to be discussed at some point. The union feels that
positions should come through this committee, subsequent to being
posted.
Notwithstanding these concerns, Mr. Erb claimed that there had
been discussions regarding the use of students at the Support Staff
Union/College Committee. It would appear that these discussions, which took
place following a downsizing within the College in 1997, related to the hiring of
students while full-time employees were on layoff. Although, in this context, the
Union raised concerns respecting students doing bargaining unit work, according
to Mr. Erb, at no time did the Union expressly state that summer students hired to
work on a full-time basis ought to be included in the bargaining unit.
In order to address the Union's concerns and provide guidance to
management as to when students could be hired under the various government
initiatives, a committee comprised of representatives of each of two Union locals
and management was struck to come up with recommendations respecting the
hiring of students. According to Mr. Erb, the committee's recommendations were
presented to the senior management team and to the President of the College.
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A number of changes were made to reflect the views of senior management and
in 1997, a policy was promulgated respecting student employment and
volunteerism. This policy, aptly entitled "Student EmploymentNolunteerism" and
included in the College's Policy and Procedure Manual as Policy/Procedure No.
P-S-9, provides, among other matters, that it is not intended that bargaining unit
work will be replaced with student employment, but rather that students will be
employed "as an enhancement to, or to assist a current position". In fact, Mr. Erb
testified that given the nature of student employment as an enhancement, if a
student were not hired, a bargaining unit position would not have been created.
Mr. Erb further testified that, once approved, Policy No. P-S-9 was
disseminated in the ordinary course to the College community, including the
Union. At no time, however, did the Union ever assert that students hired
pursuant to this policy came within the bargaining unit or were entitled to the
protections of the collective agreement. In any event, Policy No. P-S-9 provides,
in its material provisions:
Policy and Procedure Manual
Policy/Procedure No. P-S-9
Title STUDENT EM PLOYMENTNOLUNTEERISM
Sault College supports the employment of students to financially help
meet their educational costs and/or to gain valuable on the job experience.
Student employment shall be scheduled around an individual's
educational commitment and it is the intent of the College not to replace
bargaining unit work with student employment. Students may be
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employed through a variety of programs or may be employed as an
enhancement to, or to assist a current position. Exceptions shall be
reviewed with the appropriate employee group.
In the case of student hires into positions not part of a specific Student
Employment Program, a generic Student Employment Outline (attached)
must be completed and submitted to Human Resource Services prior to
hiring a student. Human Resource Services will notify the appropriate
department or employing supervisor of the status of the request following
consultation with the appropriate employee group.
It is expected that students will have only one paid position at a time and
hours of work, unless specified by program criteria, shall not exceed 15
hours per week.
The following guidelines outline the various types of programs and the
department responsible for administration:
1. Student Hires - no specific program. From time to time,
students may be required to work in positions not covered in
specific student employment programs and are funded through the
College operating budget.
Recruitment of students, once the positions have been reviewed by
Human Resource Services and the appropriate employee group,
will be carried out by the Student Placement Office.
2.a) Ontario Work Study Program. The aim of the Work Study
Program is to financially help needy students meet their educational
costs by working part-time during the school year without causing
an excessive dependence on loan funding. Hiring of students is on
a cost sharing basis - 75% paid by the Ontario Government and
25% paid by the employing departments or Student Assistance
Fund.
This program is administered by the Financial Aid Office. Financial
Aid will forward applications for OWSP position to Human Resource
Services. Human Resource Services will bring this to the
appropriate employee group. Recruitment of students will be
carried out by the Student Placement Office
b) Student Assistance Fund - This program is similar in nature and
purpose to the OWSP program and is funded through increased
tuition fees. Recruitment of students will be carried out by the
Student Placement Office.
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According to Mr. Erb, the Student Assistance Fund in Paragraph 2(b) is a
reference to the tuition fee set aside funds. Mr. Erb further testified that although
the third introductory paragraph suggests that, unless specified by program
criteria, Policy No. P-S-9 applies to positions of 15 hours per week or less, as a
practical matter, the Summer Work Program has been applied to positions of 35
hours per week.
Apart from Policy No. P-S-9, in 1998, the College (unilaterally, it
would appear) developed guidelines, which were intended to deal with the
disbursement of the tuition fee set aside funds to students in financial need under
the auspices of a program entitled "Student Bursary Program". Included in these
guidelines are different components (or "strategies") to assist with the distribution
of tuition fee set aside funds, including student employment during the academic
year (referred to as the "Sault College Work Study Program") and student
employment during the College vacation period (the "Sault College Summer
Work Program"). This document reads, in part:
Sault College Of Applied Arts and Technology
Student Bursary Program
Approved February 5, 1998
Background:
The Tuition Bursary Program was created by the provincial government as
a result of tuition increases in 1996 and 1997.
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In November of 1995 the Minister of Education announced the guidelines
for tuition increase. The announcement stipulated that the College must
reserve ten percent (10%) of the additional tuition fee revenue for student
assistance.
In 1997 the Ministry guidelines allowing institutions to increase tuition and
ancillary fees carried the requirement that any increase in fees must
reserve an additional thirty percent (30%) of the increase for student
assistance.
Each college was directed to disburse the funds to students in financial
need. No clear guidelines were established as to how the funds could be
distributed. Annual financial reports on the use of the funds are required.
Tuition Fee Bursary Committee:
The Sault College Student Bursary Committee was established in 1998·
The committee is composed of the Director of Student Affairs, the Student
Administrative Executive Committee and the Financial Aid Officer. The
Committee is mandated to review and recommend the approval of
programs and funding under the Student Bursary Program.
Student Bursary Program:
A student bursary is defined as a non-repayable award based on financial
need.
Student Bursary Program Fund Allocation:
The Student Bursary Program is funded through the allocation of tuition
fees as determined by the Ministry of Education guidelines.
The Student Bursary Program is intended to assist students in financial
need. At Sault College the fund is composed of seven distinct
components. Presently the fund consists of: 1. A cash reserve
2. Food Vouchers and or transit vouchers
3. Student Bursary Funds
4. Sault College Work Study Program
5. Sault College Summer Work Program
6. Full Tuition Bursaries
7. Textbook/Supplies Allowance
8. Textbook deferrals
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Student Bursary Fund Components:
4. Sault College Work Study Program.
Student employment on-campus through the Sault College Work Study
Program is an annual program and operated through the Placement Office
and Financial Aid. This program is a complementary employment
program to OWSP and is intended to create more employment
opportunities on campus for student [sic] with financial need. To be
eligible students must demonstrate financial need and be maintaining a
2.0 GPA. All positions are submitted through the Placement Office and
processed according to College policy.
The Committee will recommend an annual allocation of funds to the
program and seek approval of the President's Executive Committee as
part of the College budgeting process.
5. Sault College Summer Work Program.
Summer employment on-campus through the Sault College Summer Work
Program. Departments may receive funding for positions of 6 to 16 weeks
in duration. This program is designed to help students in financial need,
Students in order to be eligible must have confirmed enrollment with Sault
College and be maintaining a 2.0 GPA. All positions are submitted
through the Placement Office and processed according to College policy.
The Committee will recommend an annual allocation of funds to the
program and seek approval of the President's Executive Committee as
part of the College budgeting process.
College departments who wish to create employment opportunities on
campus must submit a written job description to the Placement Office.
This is a minimum wage subsidy program and funded at 80% with the
employer covering 20% of the wages and mandatory employment related
costs.
According to Mr. Erb, Section 5 provides that summer jobs may
extend from six to 16 weeks (whereas Policy No. P-S-9 makes no reference to
the duration of summer employment). Although Section 5 is not limited to full-
time employment, Mr. Erb testified that, as a practical matter, the only jobs which
were approved by the committee reviewing these matters were full-time jobs.
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Although Mr. Erb's evidence was unclear (as he does not deal with these matters
on a day-to-day basis), he suggested that the government subsidy for summer
employment might be 75%, rather than 80%, as indicated in the Student Bursary
Program. He also suggested that the balance is paid either by the College or by
tuition fee set aside funds. Further, although the Ontario Work Study Program
("OWSP"), referred to in Policy No. P-S-9, provides an 80% subsidy from tuition
fee set aside funds with the College paying the balance (20%), Mr. Erb testified
that this program is not designed for summer employment, but for employment
up to 10 hours per week during the school year. Finally, Mr. Erb testified that
prior to the introduction of tuition fee set aside funds, funding for student summer
employment came from the provincial government. More importantly, funds for
summer employment never came out of the College's operating budget.
Submissions for the Union
The Union submitted that the collective agreement covers a
statutorily-defined bargaining unit, the scope of which includes all employees
who are not specifically excluded. It was further submitted that there is no
exclusion for temporary employees. In fact, temporary employees (being
persons employed on a casual or temporary basis to replace bargaining unit
employees absent due to vacation, sick leave or leaves of absence) are
specifically dealt with in Appendix D to the collective agreement. Accordingly,
were summer students excluded from coverage under the collective agreement,
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as the College suggests, the College could circumvent Appendix D by hiring
summer students to replace bargaining unit employees, which could not have
been the intention. Moreover, it was submitted that the Union has a statutory
obligation to represent all employees in the bargaining unit, which would include
summer students.
Nevertheless, the Union acknowledged that it had agreed to
exclude "persons employed temporarily during the College vacation periods"
from the scope of the bargaining unit. It was submitted, however, that the
collective agreement predated the legislation and that, once the legislation came
into effect in 1975, it superseded the parties' agreement as to the scope of the
bargaining unit, as it is clear that the parties could not contract out of the
statutory bargaining unit. Furthermore, although the College claimed that the
legislative debates (known as "Hansard") demonstrate that the intent of the
legislation was to maintain the bargaining unit as defined in the existing collective
agreement, the Union claimed that the Hansard excerpt introduced in these
proceedings does not support the College's claim with respect to the support
staff bargaining unit. Furthermore, as Schedule 2 to the Act is clear on its face
as to inclusions/exclusions from the scope of the bargaining unit, there is no
reason to have reference to extrinsic evidence. In any event, the Union
submitted that Hansard should be referred to as an aid to the interpretation of
legislation only in exceptional circumstances, which do not include the
circumstances of this case.
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Submissions for the College
The College submitted that as the parties to the collective
agreement (being the Union and the Council of Regents) agreed to exclude
"persons employed temporarily during the College vacation periods" from the
scope of the bargaining unit, there is no difference arising from the
"interpretation, application, administration or alleged contravention" of the
collective agreement, which can be the subject-matter of a grievance or a
reference to arbitration. The College further submitted that the Union entered
into the agreement respecting the scope of the bargaining unit with full
knowledge of the law and cannot be allowed to resile from that agreement, which
has been renewed on successive occasions over a 30-year period. Moreover,
although the Union is only seeking a declaration that the summer student in the
Financial Aid Office was covered by the collective agreement, the effect of that
declaration would be that the wage rates under the collective agreement would
apply to summer students. In the result, fewer summer students would be hired,
which would lead to a substantial decrease in financial assistance to students in
circumstances where there was never any intention that the collective agreement
be applied to them.
The College further submitted that in order to conclude that
summer students are covered by the collective agreement, the Board would have
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to find that the statute renders Article 1.1 of the collective agreement void.
According to the College, such a conclusion is contrary to the principles of
fairness, labour relations and collective bargaining, and is not a conclusion which
is mandated by statute. With respect to the statute, the College submitted that
the Colleges Collective Bargaining Act provides wide latitude in negotiations and
allows for distinctions to be made between groups of employees, such as
probationary employees, temporary employees and summer students, and for
the parties to decline to negotiate terms and conditions of employment with
respect to a particular group of employees, such as summer students.
Accordingly, even if summer students come within the statutory bargaining unit,
so long as it does not act in a manner which is arbitrary, discriminatory or in bad
faith, the Union is permitted to exercise its representational rights by declining to
negotiate terms and conditions of employment on their behalf. Moreover,
although it might have been preferable had students been excluded from other
provisions of the collective agreement, it was open to the parties to exclude them
from the scope of the contractual bargaining unit. This is not to suggest that the
parties could have agreed to change the statutory bargaining unit. However, the
College submitted that the parties could have agreed (and indeed did agree) to a
different bargaining unit for the purposes of the collective agreement. Moreover,
the College submitted that the excerpt from Hansard which was introduced in
evidence confirms that the statute was intended to replicate the scope of the
bargaining unit that was already in place when the statute came into effect, which
excluded summer students.
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The College further submitted that in order for a board of arbitration
to negate any provision of a collective agreement that conflicts with a statute,
there must be a "contractual right" under the agreement. In this case, however,
there is no contractual right, as the agreement expressly excludes students from
the scope of the bargaining unit.
In the alternative, if the recognition clause is found to be void as
being contrary to statute, the College submitted that the Union is estopped from
asserting that the summer student hired to work on a full-time basis in the
Financial Aid Office was covered by the collective agreement, as the Union has
not demonstrated that the exclusion of summer students from the scope of the
bargaining unit would be contrary to public policy. More particularly, the College
submitted that the public interest does not require that summer students be
included in the support staff bargaining unit when the parties expressly agreed
that they not be included. The College further submitted that the Council of
Regents would not have negotiated the collective agreement in the manner in
which it did, had it known that the recognition clause agreed to in successive
collective agreements would have been found to be illegal. Accordingly, as
estoppel is a doctrine based on fairness and, as it would manifestly unfair to
allow the Union to resile from a contractual provision it has agreed to on
successive occasions over a 30-year period, the College submitted that the
Union should be estopped from taking the position that summer students are
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covered by the collective agreement until the expiry of the current collective
agreement in August, 2003.
Reply Submissions for the Union
The Union submitted in response that estoppel has no application
to the interpretation of a statute. Furthermore, estoppel would not apply, as
estoppel requires detrimental reliance, often in the form of a lost opportunity to
bargain. In this case, there has been no lost opportunity, as bargaining was
done, not by the College, but by the Council of Regents. In any event, it was
submitted that the grievance was submitted well before the conclusion of the
current collective agreement and, therefore, that the matter could have been
addressed in bargaining.
Supplementary Submissions
Subsequent to the hearings in this matter, both parties made
written submissions. For its part, the College submitted that arbitration is not the
proper forum for the enforcement of a statute and that a statute cannot be the
basis for a grievance under the terms of the collective agreement. The College
further submitted that a board of arbitration has the authority to interpret statutes
only if there is a nexus between the dispute under the collective agreement and
the statute. In addition, it was submitted that the issue of (1) whether a person is
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included in the support staff bargaining unit for the purposes of the Act and (2)
whether a person is covered by the collective agreement are separate matters,
the first being dealt with by the OLRB and the second, by a board of arbitration,
and that a finding that a person is included in the bargaining unit for the purposes
of the Act is not determinative of whether the person is covered by the collective
agreement.
The College further submitted that although Section 2 of the Act
allows for students to be covered by the collective agreement, it does not require
that they be covered. Moreover, whether or not a person is covered under the
terms of the collective agreement is determined by the terms of the scope clause
which was negotiated by the parties. It was further submitted that a statute
cannot provide either the Union or a person with the right to grieve where the
agreement excludes a person from coverage, as there would be no "difference"
which could properly be the subject of a grievance under the collective
agreement. Finally, although the College agreed that a board of arbitration may
have the authority to "read down" a provision in a collective agreement that
conflicts with the statute, it was submitted that in this case, there is no conflict
between the scope clause of the collective agreement and the statute. In the
alternative, it was submitted that a provision of a collective agreement cannot be
voided, unless it both conflicts with the statute and is contrary to public policy. In
this case, the College submitted that it is not contrary to public policy to exclude
students who are employed temporarily during the College vacation periods.
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For its part, the Union submitted that a board of arbitration has the
authority and the duty to interpret statutes. Furthermore, although the Union
agreed that a board of arbitration generally determines whether a person is an
employee for the purposes of a collective agreement, whereas the OLRB
determines whether a person is an employee for the purposes of the Act, as the
bargaining unit is defined by statute, a person cannot be an employee for the
purposes of the Colleges Collective Bargaining Act without also being a member
of the bargaining unit. Accordingly, it was submitted that it was not open to the
parties to exclude persons from coverage under the collective agreement who
are members of the statutory bargaining unit.
The Union further submitted that a board of arbitration has the
authority to "read down" a provision of the collective agreement that conflicts with
a statute, in this case, the exclusion in Article 1.1 for "persons employed
temporarily during the College vacation periods", as it conflicts with Section 2 of
the Act. Furthermore, although the Union did not dispute that (1) a board of
arbitration is not the proper forum for statutory enforcement; and (2) there must
be a nexus between the dispute under the collective agreement and the statute,
as the bargaining unit is defined by statute, the Union contended that there is a
nexus between the dispute in this case (namely, whether a student hired to work
full-time during the summer of 2000 was properly excluded from coverage under
the collective agreement) and Section 2 of the Colleges Collective Bargaining
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Act. The Union further submitted that public policy is expressed in the statute.
Accordingly, the public policy in Ontario is that students hired to work full-time
during the summer vacation period are included within the bargaining unit.
Moreover, the proviso that a benefit conferred by statute can be waived by the
affected persons is inapplicable in this case as there was no evidence of
students having waived their statutory rights.
Decision
The issue in this case whether the student hired to perform office
and clerical work in the Financial Aid Office in the summer of 2000 ought to have
been covered by the collective agreement.
With respect to this issue, reference must be made to the following
provisions of the collective agreement and Colleges Collective Bargaining Act
("CCBA"):
Collective Agreement
1. RECOGNITION
1.1 Exclusive Bargaining Agent
The Union is recognized as the exclusive bargaining agent for all
Support Staff employees of the Colleges, save and except:
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- persons regularly employed for twenty-four (24) hours per week
or less and persons employed temporarily during the College
vacation periods;
Colleges Collective Bargaining Act
PART I
GENERAL
1. In this Act and in the Schedules,
'bargaining unit' means the academic staff bargaining unit of employees or
the support staff bargaining unit of employees set out in Schedules 1 and
2; ...
'employee' means a person employed by a board of governors of a
college of applied arts and technology in a position or classification that is
within the academic staff bargaining unit or the support staff bargaining
unit of employees set out in Schedules 1 and 2;...
'employee organization' means an organization of employees formed for
the purpose of regulating relations between the employer and employees
under the Act, but does not include such an organization of employees
that discriminates against any employee because of age, sex, race,
national origin, colour or religion; ...
PART VI
AGREEMENTS
48.-(2) Where a conflict appears between any provision of an
agreement and any provision of any legislation, the provision of the
legislation prevails.
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51. An agreement is binding upon the Council, the employers
and the employee organization that is a party to it and upon the
employees in the bargaining unit covered by the agreement.
52. Every agreement shall be deemed to provide that the
employee organization that is a party thereto is recognized as the
exclusive bargaining agent for the bargaining unit to which the agreement
applies.
PART IX
REPRESENTATION RIGHTS
65. Every person is free to join an employee organization of his
or her own choice and to participate in its lawful activities.
67. The bargaining units set out in the Schedules are the units
for collective bargaining purposes under this Act.
SCHEDULE 2
The support staff bargaining unit includes the employees of all
boards of governors of colleges of applied arts and technology employed
in positions or classifications in the office, clerical, technical, health care,
maintenance, building service, shipping, transportation, cafeteria and
nursery staff but does not include,
(vi) persons regularly employed for not more than twenty-four hours a
week,
Section 1 of the Colleges Collective Bargaining Act provides a
definition of "bargaining unit" as including the support staff bargaining unit set out
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in Schedule 2, and a complementary definition of "employee" as a person
employed within the bargaining unit set out in Schedule 2. Schedule 2 defines
the support staff bargaining unit as being "the employees of all boards of
governors of colleges of applied arts and technology employed in positions or
classifications in the office, clerical, technical, health care, maintenance, building
service, shipping, transportation, cafeteria and nursery staff", with certain
specified exceptions, including an exception for "persons regularly employed for
not more than twenty-four hours a week" (Para. vi). Although the recognition
clause under the collective agreement includes an exception for "persons
regularly employed for twenty-four (24) hours per week or less", it also provides
an exclusion for "persons employed temporarily during the College vacation
periods" (Art. 1.1) (generally referred to as "students"), which is not found in the
statute.
VVhile the parties to a collective agreement are generally free to
determine the scope of the bargaining unit, where (as in this case), the
bargaining unit is prescribed by statute (CCBA, S. 67), the parties cannot deviate
from the statutory bargaining unit, as in this case, by agreeing to an additional
exclusion: see Re La Cit~ Coll~giale and The Ontario Pubfic Service Employees
Union; Ga~tanne Caron Grievance, February 10, 1997 (M.G. Picher
(unreported)) ("La Cit~ (Caron)"); Waito v. La Cit~ Coll~giale Ottawa and Ontario
Pubfic Service Employees Union [1998] OLRB Rep. 636 ("La Cit~ (Waito)").
Moreover, although the College seemed to suggest that the proscription against
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deviating from the statutory bargaining unit does not prevent the parties from
agreeing to a different bargaining unit for the purposes of the collective
agreement, the Board cannot agree. As these cases confirm, where there is a
statutory definition of the bargaining unit, the contractual bargaining unit must
conform to that definition, and where there is a conflict between the definition of
the statutory and contractual bargaining units, the statutory definition prevails
(CCBA, Ss. 48(2)).
In La Cit¢ (Caron), the grievor was hired on a series of successive
contracts under which she was regularly employed for more than 24 hours per
week over a period of almost three years. Although both parties accepted the
grievor's exclusion from the bargaining unit, the board found that she could not
be excluded, as she came within the general description of the bargaining unit
and did not fall within any of the statutory exceptions (the relevant exception in
that case being "persons regularly employed for not more than 24 hours per
week"). The board's reasoning is set out, in part, at p. 9 of the decision as
follows:
To begin, we find it important to acknowledge that the legal framework in
which the Collective Agreement is set. This is not a bargaining unit or a
collective agreement that the parties can reconstruct or amend as they
see fit. In the administration of their Collective Agreement, the College
and the Union are bound to observe the provisions of the Colleges
Collective Bargaining Act, R.S.O. 1990, Chap. C. 15. In particular, they
cannot deviate from the provisions of the Act precisely defining the word
'employee' and clearly describing the bargaining unit.
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It goes without saying that the parties may not, by their own practice or
understanding, rescind the legal status granted to an individual by law ....
A similar conclusion was reached in La Cit~ (Waito), which involved
a complaint under the Labour Relations Act. The substance of the complaint,
which was brought by Ms. Waito, was that the college and the union had
breached the Colleges Collective Bargaining Act in treating her as a contract
employee, rather than as a member of the bargaining unit, for the duration of her
employment in the campus bookstore. The essential dispute centred around
whether Ms. Waito, who had been hired on a series of successive contracts over
a three-year period, ought to have been considered to be a member of the
support staff bargaining unit represented by OPSEU when the college terminated
her contract in June, 1994. After referring to the recognition clause in the
collective agreement, as well as a number of statutory provisions (namely, the
definition of "employee" in Section 1, Section 52, Section 67, and the description
of the bargaining unit in Schedule 2 to the Colleges Collective Bargaining Act),
the OLRB commented as follows:
59. Section 67 provides that the bargaining units set out in the statute
are the bargaining units for collective bargaining:
67. The bargaining units set out in the Schedules are the units
for collective bargaining purposes under this Act.
60. Read together these statutory provisions give OPSEU the right and
obligation to represent employees in the described bargaining units and
employees in those bargaining units have the right to be so represented.
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62. The effect of the above statutory provisions, is that people working
the number of hours at the kind of tasks that Ms. Waito did for three years
are in the bargaining unit, and represented by OPSEU, by force of law.
None of the listed exceptions apply [sic] to the facts of this case ....
Employer counsel argued.., that the parties were free to treat positions
as not in the bargaining unit, . . . That proposition may be valid in a
situation where the parties are free to determine the scope of the
bargaining unit between them. However, I am not persuaded that it has
any validity where the statute prescribes the bargaining unit. It is trite law
that the parties cannot contract out of a statute. The statute, not the
parties' consent, gives rights to individual employees to be in the
bargaining unit and to be represented by a bargaining agent, as well as to
the union to represent those employees.
Although the College submitted that the La Cit¢ decisions are
distinguishable as the employees in those cases had statutory and contractual
rights to representation, which the parties failed to recognize, whereas the
student in this case had no contractual right to representation, in the Board's
view, this is a distinction without a difference. VVhile different means were used,
in this case, as well as the two La Cit¢ cases, employees were improperly denied
their statutory rights (in this case, by means of a provision which was negotiated
in the collective agreement and, in the La Cit~ cases, by applying the agreement
in such a manner as to exclude the employees from coverage).
In contrast, in the context of a finding that the parties never
intended that continuing education teachers be covered by the collective
agreement, the board in Re Ontario Pubfic Service Employees Union and
George Brown College; Grievance of L.D. Benhaggai, February 16, 1993
24
(Mitchnick (unreported)) ("George Brown") held that it was not within its
jurisdiction to determine whether the Colleges Collective Bargaining Act provided
such coverage. It is generally recognized, however, that boards of arbitration
have not only a duty, but an obligation, to construe and apply the relevant statute
law to the terms of a collective agreement and, where a conflict is found between
the terms of a collective agreement and a statute, to apply the statute: see
McLeod v. Egan, [1975] 1 S.C.R. 517, 46 D.L.R.(3d)150 (S.C.C.). In addition,
the Colleges Collective Bargaining Act expressly recognizes the primacy of the
statute in Subsection 48(2) by providing that "[w]here a conflict appears between
any provision of an agreement and any provision of any legislation, the provision
of the legislation prevails". Although the College submitted that in order for
Subsection 48(2) to have application, there must be a "contractual right" which
conflicts with a provision of a statute, Subsection 48(2), on its face, applies to
"any provision of an agreement", irrespective of the nature of the provision and,
in particular, whether it is a provision which confers or, in the case of the
exclusions under Article 1.1 of the agreement, abrogates rights. To the extent
the George Brown decision is inconsistent with the Board's obligation to consider
the impact of public statutes in interpreting the provisions of the collective
agreement and with the two La Cit¢ decisions, which considered the impact of
the statute, the Board declines to follow it.
The College suggested in its written submissions that arbitration is
not the proper forum for the enforcement of a statute. However, this is not a
25
case of statutory enforcement where there is no connection to the collective
agreement. Rather, the issue in this case concerns the interpretation of the
collective agreement within the context of the statutory framework, which the
Board is empowered to construe. Moreover, contrary to the assertion of the
College, this is not a case in which the statute allows for membership within the
bargaining unit, but rather requires membership with certain specified exclusions.
Furthermore, as to the suggestion that the issue in this case comes within the
jurisdiction of the OLRB, rather than a board of arbitration, where there is a
statutory definition of the bargaining unit, as in this case, there can be no doubt
as to the Board's jurisdiction, as a member of the statutory bargaining unit must
be included within the contractual bargaining unit. Finally, as to the suggestion
that there is no arbitrable "difference", which can properly be the subject of a
grievance, the difference relates to the interpretation of Article 1.1 of the
collective agreement, which must be construed in accordance with Schedule 2 to
the Colleges Collective Bargaining Act. Put another way, Article 1.1 provides the
necessary nexus to confer upon the Board jurisdiction to interpret the statute.
Furthermore, the College suggested that Hansard confirms that the
statutory bargaining unit was intended to conform to the bargaining unit as
described in the collective agreement at the time the statute came into effect,
which would exclude "persons employed temporarily during the College vacation
periods". Although the Supreme Court of Canada has recognized that Hansard
may be considered in ascertaining the purpose for which legislation was enacted,
26
it is not evidence of legislative intent (Rizzo & Rizzo Shoes Ltd. (Re), [1998] 1
S.C.R. 27; Reference re: Firearms Act (Can.), [2000] 1 S.C.R. 783). Accordingly,
notwithstanding the Government's professed intention in the excerpt submitted
from Hansard to design legislation around the provisions of the collective
agreement then in effect, the fact that the statute fails to exclude "persons
employed temporarily during the College vacation periods" from the scope of the
bargaining unit must be taken as a clear indication of legislative intent that
students be included.
In the result, the Board finds that the purported exclusion of
"persons employed temporarily during the College vacation periods" from the
scope of the bargaining unit is contrary to statute and cannot stand. Although the
College submitted that a provision of a collective agreement cannot be voided
unless it conflicts with the statute and, in addition, is contrary to public policy, in
the present case, it seems clear that the statute is the expression of public policy.
Although there may be circumstances in which a statutory provision may be
waived by a class of persons for whose sole benefit the provision was intended,
even assuming that the statutory protection for students was intended for their
benefit alone, there was no indication of any student having waived this benefit.
Furthermore, although an agent may waive a provision for the benefit of its
principals, at the time the exclusion for "persons employed temporarily during the
College vacation periods" was agreed to, there was no evidence that the Union
27
was acting as agent for any student. Accordingly, the Board finds the exclusion
to be void.
Nevertheless, the College claimed that the Union is estopped from
asserting that the summer student hired to work on a full-time basis in the
Financial Aid Office was included in the support staff bargaining unit. The
doctrine of estoppel was enunciated by Denning L.J. in Combe v. Combe, [1951]
1 All E.R. 767 at p. 770 as follows:
The principle, as I understand it, is that where one party has, by his
words or conduct, made to the other a promise or assurance which was
intended to affect the legal relations between them and to be acted on
accordingly, then, once the other party has taken him at his word and
acted on it, the one who gave the promise or assurance cannot afterwards
be allowed to revert to the previous legal relations as if no such promise or
assurance had been made by him, but he must accept their legal relations
subject to the qualification which he himself had so introduced, even
though it is not supported in point of law by any consideration, but only by
his word.
It would appear that, by negotiating a provision, which would
exclude "persons employed temporarily during the College vacation periods"
from the scope of the bargaining unit, in successive collective agreements over a
30-year period, the Union made a representation to the College, which was
intended to affect legal relations and to be acted upon by the College. Moreover,
although it is at least arguable that, by hiring students at the minimum wage
(rather than the wage set out in the collective agreement), the College relied on
that representation to its detriment, the Union maintained that there can be no
28
detrimental reliance, as it was foregoing its claim to retroactive wages and,
further, as there was no evidence of a lost bargaining opportunity.
Certainly, it would seem fair, given the effluxion of time, to give
effect to an estoppel argument. However, even aside from the issue of
detrimental reliance, it is generally accepted that estoppel cannot be invoked
where allowance of the estoppel would result in an illegality: see, e.g., Re Natrel
Inc. and Milk and Bread Drivers, Dairy Employees, Caterers and Allied
Employees, Teamsters Loc. 647 (Pecchia) (2000), 91 L.A.C.(4th)438 (Charney).
In this case, as has been found, the exclusion of "persons
employed temporarily during the College vacation periods" from the scope of the
bargaining unit is contrary to statute. Nevertheless, the College submitted that
there is no impediment to allowing the estoppel as it was open to the Union to
waive or contract out of the statute, as there is no public policy interest to be
protected by having students included within the bargaining unit. In support of its
position, the College relied on the decision of the OLRB in Ontario Hydro [1990]
OLRB Rep. 305. In that case, the parties agreed that a number of agreements
reached between them did not constitute a "collective agreement" to which the
Labour Relations Act applied. When the union attempted to resile from that
position, the OLRB found that there was no public interest in requiring that the
agreements be treated as a collective agreement when the parties had expressly
agreed otherwise, and applied the doctrine of estoppel to prevent the union from
29
asserting that the agreements were covered by the Labour Relations Act. In the
Board's view, there are significant differences between this case and Ontario
Hydro. In Ontario Hydro, in which there was a certification application pending,
there was no statutory requirement that the parties enter into a collective
agreement. Accordingly, the parties were able to agree not to have a collective
agreement and their agreement was not contrary to public policy. In contrast, as
has been found in this case, there is a statutory description of the bargaining unit,
which does not exclude students and, therefore, the parties' agreement to
exclude students from the scope of the bargaining unit is contrary to public
policy, as expressed in the statute. This finding would appear to be consistent
with the view of the OLRB in the La Cit¢ (Waito) decision, wherein it was stated
at para. 116:
·.. whatever the parties may be free to agree on, or rely on estoppels for,
where there is no statutory bargaining unit, I remain unpersuaded that
such a route is open where there is a statutory bargaining unit. This is
further supported by section 48(2) , which explicitly sets out the
primacy of the statute over any agreement.
Although this reasoning is obiter, as no finding was made as to whether the facts
of that case would support an estoppel, it seems clear that the view expressed by
the OLRB represents an accurate statement of the applicable law.
It does not necessarily follow, however, that, because students are
included in the bargaining unit, they are covered by the terms of the collective
agreement. It seems clear that, having excluded students from the scope of the
30
bargaining unit (albeit improperly), the parties never intended that terms of the
agreement would apply to them. In fact, students, who are hired for a specified
term can be distinguished from regular full-time employees, who are hired on an
indeterminate basis. In this respect, this case differs from the two La Cit~ cases.
In those cases, once it was determined that the employees in question (Ms.
Caron and Ms. Waito) were improperly excluded from the bargaining unit on the
basis that they were hired on a series of successive contracts, they were
indistinguishable from regular full-time employees and, therefore, covered by the
terms of the collective agreement. In this case, however, there is a significant
difference between students who are hired to work full-time during the College
vacation period and regular full-time employees who are hired on an
indeterminate basis. Accordingly, although it has been determined that students
were improperly excluded from the bargaining unit, it is unclear as to the manner
in which the collective agreement ought to be applied to them. It should be
mentioned in this regard that it is not uncommon for special arrangements to be
made in relation to students. Moreover, although students were not
contemplated as being covered under this agreement, the parties have made
separate arrangements for other groups of employees, most notably, temporary
employees, who are dealt with under a separate Appendix to the collective
agreement (Appendix D).
In the result, as requested, the Board declares that students come
within the scope of the support staff bargaining unit and, therefore, that the
31
exclusion for "persons employed temporarily during the College vacation periods"
is void as being contrary to statute. However, the Board remits the matter of the
terms and conditions applicable to these employees for the parties to deal with,
and remains seised in the event they are unable to do so. As well, the Board
remains seised to deal with matters of implementation and with any remedial or
other issues that may arise in relation to this grievance.
DATED AT TORONTO, this 19th day of February, 2002.
"Maureen K. Saltman"
Chair
"1 concur- David Cameletti"
College Nominee
"1 concur- Edward Seymour"
Union Nominee