HomeMy WebLinkAbout1988-1357.Union & Ansara.92-04-15 ONTARIO . EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L 'ONTARIO
GRIEVANCE C,OMMISSION DE
'S TTLEMENT REGLEMENT
BOARD DES GRIEFS
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1357/88, 1426/88
IN THE HATTER OF AN ARB'rTRATZON
Unde~
TUn (3R.3:FT'ANCB 8ETTLRI~HT BOARD
BETWEEN
OLBEU (Union Grievance/Ansara)
- amd -
The Crown in Right of Ontario
(Liquor Licence Board of Ontario/
Liquor Control Bo.ard of Ontario)
Employer
BEFORE: R. Verity Vice-Chairperson
J.. McManus Member
D. Daugharty Member
FOR TH~ C. Flood
QRIEVOR Counsel
Koskie & Minsky
Barristers & Solicitors
FOR THE G. Luborsky
EMPLOYER Counsel
Hicks, Morley, Hamilton, Stewart, Storie
Barristers & Solicitors
HEARING July 19, 1989
December 5, 7, 1989
~., May 22, 23, 1990
July 10, 11, 12, 1990
March 21, 22, 1991
July 3, 4, 1991
December 6, 1991
2
DECISION
In this matter, a union policy grievance da~ed January 11,
1989 and an individual grievance filed by George Ansara dated
January 23', 1989 arise from the posting of a position in October
1988 for "A" Store Assistant Manager at Store #58 at Timmins
(Competition %NR1/88). The vacancy was created in May 1988 when
Lucien Cloutier,.a fully bilingual employee, was transferred from
Assistant Manager at Store %58 to Manager of Store 9592, a "C"
Store in Timmins.
The dispute foCuses on the "reasonableness" or the "need" for
the stated qualification in the job posting in question -
""intermediate oral French Language skills required". Mr. Ans~ra,
the. senior applicant, was denied the position for the sole reason
that, in the opinion of management, he lacked the requisite French
Language skill. The grievor's seniority date is December 18, 1972.
Marc Bussiere, a fully bilingual employee, was awarded the
Assistant Manager's position effective February 27, 1989. Mr.
Bussiere'was in attendance at the hearing and was accorded full
rights to participate. His seniority date is December 29, 1975.
In essence, both grievances allege a violation of the
provisions of Article 21.5(a) of the collective agreement.
However, at the hearing, the Union amended its policy grievance by
3
adding a violation of the "Letter of.Agreement, French Language
Services". The Un~on introduced evidence of negotiating history
allegedly to resolve an ambiguity in the Letter of Agreement and to
ground an estoppel. It is important to note that the union
challenges neither the validity of the French Language Service Act,
1986 nor the L.C.B.O.'S Implementation Plan for the provision of
French Language services.
The following provisions of the collective agreement are
relevant:
ARTICLE 21
Assignments and Job ~ostings
2115 (a) Where employees are being considered for'~romotion,
seniority will be the determining factor provided
the employee is qualified to perform the work.
***LETTER OF AGREEMENT***
FRENCH LANGUAGE SERVICES
In expanding its French language services the Boards agree to
the following:
1. To make reasonable effort to minimize adverse effects on
employees which may be caused by the designation of
bilingual positions.
2. To keep the Union apprised of the Boards' implementation
plans.
3. To provide the Union with an opportunity to review any
policy being proposed for French language training
applicable to bargaining unit employees. Employees
directed by the Boards to undertake French language
training shall do so at the Boards' expense and without
loss of pay or creOits.
4. To provide the Union with a list of all worksites at
which the Boards are required to provide service ~n
French in accordance with government or Boards' policies.
Information will be p~ovided as to the method by which
the services will be provided at each worksite'. -
5. The designation of bilingual positions, the standards of
fluency required, the training courses developed for
bargaining unit employees and other related concerns
shall be referred for discussion to the committee
specified under Article 1.8 of the Collective Agreement.
The parties agree that Article 21.5(a) is a threshold ability
clause whereby the senior employee, if qualified, is entitled to
the job. It was agreed that'Mr. Ansara was qualified fDr the
position except for the requisite level of French Language
proficiency.
Fluency in the French Language is not a requirement at the
intermediate level of French proficiency. In fact, the only levels
considered "functional" are "advanced" and "superior''. At the
intermediate level, the government's expectation is'relatively low
and is expressed as follows:
"At this level one possesses some ability to work in French.
One 'shows some spontaneity in .language production, but the
fluency is very uneven resulting in halting speech. One is
able to participate in simple conversations on a one-to-one
basis. The vocabulary is limited to that used in simple, non-
technical, daily conversational usage. One can make and
answer requests of information or directions,~ give simple
5
instructions and discuss simple needs. When addressing this.
person the speaker may have to slow down and repeat if'he/she
wishes to be understood."
Some background infOrmation may be helpful to understand the
sensitive nature of this dispute. These grievances arise in the
context of the French Lanaua~e Services Act, 1986 which' was
assented to on November 18, 1986. The Ac~ established the right to
communicate in French and receive services in French from Ontario
Government offices in designated areas of the Province. The
District of Cochrane, which includes the City of Timmins, is one of
.'the designated areas. Store ~58 is the ~nly "A" Store in District
~3 and the only designated store of the three liquor stores within
the Timmins area.
Under s.2 of the French Language Services Act, 1986, the
Government of Ontario has a mandate to "ensure that services are
provided in French in accordance with this Act". Under's.12 of the
Act, the Minister responsible for Francophone Affairs has the
statutory obligation "for the administration of this Act". There
is, however, provision in the Act for a three year phasing in
period With full services to be in place effective November 18,
1989.
Jane Holmes was L.C.B.O. acting French L~nguage Services Co-
ordinator between January 1987 .and August 1988. She testified that
the L.C.S.O., under the direction of the Ministry of Consumer and
6
Commercial Relations, was cognizant of its responsibility to
provide French services "as the most .visible arm of the Ontario
Government". Similarly, it was sensitive to the need to minimize
adverse effects· of the legislation on the existing employee
complement. In early 1987, the L.C.B.O. conducted an employee
survey, in reality an individual self-assessment, to determine the
extent of existing oral and written French proficiency.
According to Ms..Holmes, the result of the survey established
that the L.C.B.O. would be unable to provide French services in all
251 liquor stores located in designated areas by November i8, 1989.
Criteria were developed to determine which stores within the
designated ar~as would provide "equal ·services in French and
English". Eventually, 114 designated stores were identified
including Store #58 at Timmins. The results of the self-assessment
survey were used by the. L.C.B.0. to determine the number of
"bilingual" staff available and required at each of the designated
stores. Apparently the number of bilingual employees required at
a particular store was established on the basis of the store
classification, hours of operation and scheduling considerations.
At Store %58 ~in Timmins, it was determined that of an employee
complement of 14 (eight permanent and six temporary) six permanent
staff members and one temporary employee were "bilingual" and that
the actual number of "bilingual" employees required was five.
Those figures were included in the L.C.B.0.'s Implementation Plan
of December 1987 (Exhibit 21) and remained unchanged in the Mid-
7
Term Corrections Plan dated September 12, 1988 (Exhibit 22). Ms.
Holmes testified that in the spring of 1987, at the instigation of
the Union, the parties met with the Office of Francophone Affairs
to reinforce the Union's concerns about the legislation and ~n
particular the potential .for ~ob loss.
In December, 1987, the L.C.B.0. submitted its French Language
Services Implementation Plan to the Office of Francophone Affairs
(Exhibit 21). The plan was prepared exclusively by the Employer,
without Union input. The L.C.B.O. obtained approval from
Francophone Affairs for "an undesignated Human Resources plan" for
retail stores which would focus on the number of "bilingual"
emplpyees required in each designated, store rather than the
designation of~ a p~sition per se. Therefore, in a design~ated
store, each vacancy had to be carefully evaluated as to the number
'of "bodies" with Frenchlanguage skills in orde~ to provide service
during all operationalLhours. Ms. Holmes testified that based on
the self-assessment survey, the ~.C.B.O,"lacked sufficient numbers
of employees at the ,advanced" and "superior" level of French
proficiency. In these circumstances, the Offic~ of Francophone
Affairs reluctantly agreed that "a strong intermediate French
language proficiency" would serve the needs of French speaking
customers in liquor stores. However, Francophone Affairs made it
clear that they would continue to monitor and audit the situation.
The L.C.B.O. developed a French language proficiency test with the
help of an outside consultant to-assess the level of French
8
language skills. Employees were trained.to administer the test, as
for example, in the northern region, Camille Clements-Pitchkur and .
Don Thibodeau.
With the above background information, we turn now to cHnsider
the evidence. We might say that this arbitration proceeded at
great length, during 13 hearing days. To consider every piece of
evidence that was raised would carry this decision beyond
o
reasonable bounds.
The grievor, George Ansara, has been Assistant Manager at
Store #592, a "C" Store at Timmins, since 1981. Previously he
worked for approximately eight years at Store ~58 and briefly at
Store #128,~°a "C" Store in adjacent South Porcupine.' The grievor.
testified that he had high school French and worked as a salesman
in the French language some 20 years ago. In his opinion, he had
a working ability in the French language at the intermediate level.
The grievor was tested i'n oral French proficiency on November 28,
1988 by District Manager Don Thibodeau. Apparently the test is
designed to evaluate oral comprehension an~ oral competence in the
French Language. The grieuor testified that he scored 13 out of a
possible 14 in oral comprehension, which he described as "the
picture test". He recalled that the oral competency component was
tape recorded and took the form of a conversation in French. In
the grievor's words "I found the test quite reasonable" and he
answered the questions "fairly well or quite well" The grievor
9
had some difficulty recalling the sequence of events in this matter
which is not surprising given the passage of time. In particular,
he did not recall receiving the letter of December 21, 1988 from
Don Thibodeau (Exhibit 9) advising that he (the grievor) had not
met the French language requiremgnt. The grievor maintained that
while he is "not fully bil'ingual", he can make himself understood
in the French language.
Ted Zajac is Assistant ~Manager of Store #128 at South
Porcupine. He was the third applicant for the position in
ques{ion. Mr. Zajac testified that he was not interviewed for the
job because he was the junior applicant and did not speak French.
Lucien Cloutier, a bilingual employee, is'Manager of Store
~592 in Timmins. He testified that when he worked as Assistant
.Manager at Store ~58 (until May 1988), there were five bilingual
full-time employees; namely, Manager Paul Pilon, the two Assistant
Managers Guy Pich~ and himself, Marc Bussiere, then Clerk 4 a~d Art
Chartier, then Clerk 3. He later testified that Bob Fritz, a Clerk
3 whose first language was English, had passed "a bilingual test"
so that technically there were six bilingual employees at Store
~58. Mr. Cloutier recalled that he had observed the grievor
perform in French· "a few times" and that "he (the grievor) tries
his best" ' However, Mr. Cloutier refused a request by District
Manager Don Thibodeau to write a letter as to the grievor's abilitY
to speak French. In cross-examination, Mr. Cloutier justified his
10
refusal on the basis that he had no involvement in French Language
prQficiency testing.
John Miles was President of the Union. He gave detailed
evidence of collective ~egotiations between .the parties that lead
to the introduction of the Letter of Agreement, French Language
Services. The Letter of Agreement was agreed to on February 14,
1987. Mr. Miles testified that the Union had a number'of concerns
as to the effect of' the French Language Services Act. 1986
including lay-offs, the impact of the Act on current employees, the
designation of positions requiring French language proficiency, the
restriction of promotional opportunities for unilingual employees
and the possible "parachuting" into positions by new bilingual
employees. The Union's initial positioh was tabled on October 2,
1986 which requested the inclusion of a new. article in the
collective agreement entitled "BiIingual Bonus" (Exhibit 12) as
follows:
5) New Article - Bilingual Bonus
Create a new article which contain the following provisions:
a) a substantial monetary bonus for Board employees occupying
bilingual positions;
b) bilingual training courses during working hours for
interested unilingual Board employees,
c) provision of a list containing all worksites where
bilingual positions wili exist in accordance with government
policy.
11
The Employer did not agree with that proposal in any respect.
Mr. Miles candidly acknowledged that when the F=ench Language
Services "letter" was agreed to on February 14, 1987 the Employer
had no policy or guidelines in place and was "unclear" as to the
level of French language proficiency that would be acceptable to
the Office of Francophone Affairs. Mr. Miles testified that during
negotiations, the Employer agreed to make reasonable efforts to
minimize adverse effects on the existing employee complement and,
in general, adopted a stance of "trust-us" Mr. Miles recalled
that in February 1987 the Employer had no implementation plan then
in effect and was .unsure as to the demands of the Office of
Francophone Affairs.
Camille Clements-Pitchkur is Co-ordinator of Human Resource
Service for the L.C.B.O.'s Northern Region. She testified that
Store %58 at Timmins is the only "A" Store of 22 liquor stores in
District %3. Store %58 is a designated store.with a two shift
operation (day shift and afternoon shift) with operational hours
from 9:30 a.m. to 10:00 p.m. Monday to ~riday and from 9:30 a.m. to
6:00 p.m. on Saturday. Mrs. Clements-Pitchkur testified that the
L.C.B.0. had an obligation to ensure that during operational hours
Store #58, as a designated store, must provide "equitable" customer
services in both English and French. In her words "from a staffing
standpoint, we had to have at least one staff member on hand to
.respond to the needs of a client who might request services in
F-rench". She stated that although Store ~58 had a "1-800 toll free
12
number" to provide telephone service in French, "it was an
alternative but not a substitute" for employea service.
· Mrs. Clements-Pitchkur viewed the vacancy at Store #58
from
the standpoint of being+a designated store, the existing full-time
staff c~mplement with French language skills (four employees) and
the scheduling demands. After considering a number of options, she
concluded that equitable services could not be provided without a
French language designation conta£ne'd in the posting. She
maintained that Store 958 employee Bob Fritz was not sufficiently
proficient to meet the standards of either the Office of
Francophone %ffairs-or the L.C.B.0. Although Mr. Fritz had not
'i. applied for the vacancy in question, he had been previously tested
for French language skills and had failed 'to achieve a strong
intermediate level grade. She described the reason for preparation
of at least two and possibly three postings in this competition.
However, all three applicants were considered for the position, in
· ~er words because of the "ambiguity" of the posting notices.
M~-s. Clements-Pitchkur described in some detail the French
'language testing procedure developed by the L.C.B.0. Briefly
stated, under the oral competency section, candidates are tested
for language delivery, ability to make oneself understood,
vocabulary, grammar and pronunciation. Without knowledge of the
mark assigned the grievor by Mr. Thibodeau, Mrs. Clements-Pitchkur
evaluated the grievor's tape. In assigning a mark of 9 out of 50,
13
she concluded that the grievor had failed the test. She stated
tha~ a mark of 10 was the minimum requirement for the intermediate
level and that a mark of 12-14 would indicate strong intermediate
French language skills. Mrs. Clements-Pitchkur forwarded the taPe
to Jacques Bastien, then L.C.B.O. Co-ordinator for French Language
Services. Apparently, Mr. Bastien assigned a mark of 8. out of 20.
Subsequently, Mrs. Clements-Pitchkur evaluated a tape of Marc
Bussiere's oral competency test and was satisfied that he surpassed
the minimum requirement.
Don Thibodeau, as District Manager, was part of the decision
to post the vacancy with the French language qualification. He
testified that with a full-time staff complement of four.who had
French langu&ge skills there was no alternative bu~ to post with
the language qualification based on employee rights under the
collective agreement, the hours of operation and the normal
scheduling pattern. He had previously evaluated the French
language skills of the four empl6yees. In cross-examination, Mr.
Thibodeau acknowledged that in assessing the need for the French
language qualification only permanent full-time emplOyees were
considered. In other words, casual employees and permanent part-
time employees were not considered in scheduling concerns. In
assessing the grievor's oral competency, Mr. Thibodeau stated that
the grievor's delivery "was his one strong area" but that he had
difficulty with vocabulary and grammar and would frequently revert
to English. Mr. Thibodeau assigned the grievor a mark of 9 out of
14
20 and concluded that he lacked the requisite French language
skills. He then forwarded the tape to Camille Clements-Pitchkur
for an independent assessment. Subsequently he evaluated Marc
Bussiere using the same test and concluded that Mr. Bussiere had
the requisite French language skills.
In reply evidence, Union Vice-President Gord Gerrard,
currently a "B" Store Assistant Manager in Mississauga, introduced
a .number of schedules to il'lustr~te that it was possible to '
schedule one employee on each shift with the requisite French
language skills (Exhibit 38).
Essentially, there.are two central issues in this case;
namely, (1) whether the designation of French language skills in
the posting was "reasonably related" or "necessary" to the position
in question; and (2) whether the testing was fair and reasonable.
We make no attempt.'to repeat the able submissions of Counsel
except in summary form. The Union contended that neither g~ievance
involved opposition to bilingualism or to th~ legitimate extension
of.French Language services'. Mr. Flood argued that in light of
Article 21.5(a) of the collective agreement, the appropriate
standard of review was the hiqher standard of necessity. In the
alternative, the French language qualification was not reasonably
related to the job. In the further alternative, the grievor
possessed the requisite language skill or that the process was
15
flaWed. Mr. Flood argued that negotiating history was admissible
to resolve an ambiguity in the words "reasonable effort" in the
phrase "reasonable.effort to minimize adverse effect'on employees
which may be caused by the designation of bilingual positions" as
.contained in paragraph 1 0f the Letter of Agreement. He also
contended that John Miles' evidence was relevant to ground an
estoppel on the basis that a number of broad statements were made
by management and that the L.C.B.O. would make reasonable effort in
effect to redress the wrongs of the past. In support, the Union
cited the following authorities: OPSEU (Giasson) and Ministry of
Labour 2250/87 (Devlin) (Interim Decision); OPSEU (L. MacKenzie)
and Ministry of' Transportation and Communications 1243/87
(Ratushny) (Interim Decision); OPSEU (Dalv) and Ministry of Tour£sm
and Recreation 1440/88' (Samuels); OPSEU '(St. Pierre) and Ministry
of Transportation 1236/89 (Verity); Canadian Food and Allied
Workers Union; Local 175 v. Great Atlantic and Pacific Company of
Canada Limited et al 76 CLLC 332 (Ont. Div. Ct.); OPSEU (L.
MacKenzie) and Ministry of Transmortation and Communications
1245/87 (Ratushny) (Final Decision); OPSEU (G. Giasson) and
Ministry of Labour 2250/87 (Watters) (Final Decision); and R~e
Eastern Provincial Airways (19631 Ltd. and Canadian Airline
EmploYees' Association (1979), 24 L.A.C. (2d) 71 (Christie).
The Employer urged the panel to view these grievances in the
context of the French Languaqe Services Act, 1986 and in light of
the operational requirements of the only designated store in
16
Timmins, a city wi~h a substantial Francophone population. Mr.
Luborsky acknowledged G.S.B. jurisprudence that a panel has
jurisdiction to determine whether a job qualification, is reasonably
related to the job. However, he argued that under s.18(1) of the
Crown Employees Collective Bar~aininq Ack that once it is
established that the L.C.B.O. was implementing government policy in
good faith, a panel has no further jurisdiction. In the
alternative, Mr. Luborsky argued that the Standard of review deemed
appropriate was the standard of reasonableness and not necessity.
He argued that the extrinsic'evidence adduced was not probative and
that there was.no ambiguity in the Letter of Agreement and no basis
for the application of an estoppel. In sum, the EmplOyer urged a
finding that the. French language qualification ~s totally
appropriate i~ these circumstances and that the grievor was
unsuccessful based on his ability to meet the language
qualification. The following authorities were cited: OPSEU
{Carroll LaDraik) and Ministry of the Attorney General 657/84
(Draper); 0PSEU (Beck) and Ministry of Government Services 196/89
(Watters); OPSEU (Moses) and Ministry of Consumer and Commercial'
Relations 715/89 (Barrett); and Re Ontario Hydro and Canadian Union
of Public EmDtoYees, Local 1000 (1987), 30 L.A.C. (3d) 331 (Brent).
In our view, there is no ambiguity in the Letter of Agreement,
French Language Services. If we are wrong in. that regard, we must
say that the extrinsic evidence offers no assistance in the
resolution of the matter and accordingly is of no probative value.
17
The Letter of Agreement came into effect on February. 14, 1987 in
the absence of any L.CoB.O. policy, guideline or Implementation
Plan. During negotiations the Union addressed legitimate concerns
on behalf of its membership on the effect of the new Act. However,
the L.C.B.O. made it clear, to the Union that the Implementation
Plan was in the formulation stage and that the'Plan proposed would
have to be negotiated with the Office of Francophone Affairs.
Similarly, on the evidence adduced, there is no basis to ground an
estoppel 'in the absence of any firm representation on the part of
the L.C.B.O. At best, during negotiations, the Union was made
aware of the approach that the L.C.B.O. was likely to follow, and
of its intention to advance the merits of an'undesignated.human
resources plan. ..
The job posting in question must be viewed in the reality of
the French Languaqe Services Act, 1986, the fact that Store 858 is
the only designated store in the Timmin$ area, the fact that the
District of Cochrane is a designated area under the Act and the
fact that the City of Timmins has a Francophone population of
approximately 45%.
Under the management.rights provision of s.18(1) of the Crown
Employees Collective Barqainin~ Act, the Employer has the right to
establish qualifications required to perform a particular job. It
is now well established that the appropriate standard of review is
to ensure that a particular qualification is reasonably related to
18
the job in question. See for example, MacKenzie and Ministry of
Transportation and Communications, supra, (Ratushny) and (Giasson)
and Ministry of Labour, supra, (Watters). We are Unable to agree
with the Union's principal argument that the standard of review in
these particular circumstances should be one of necessity.
In the case before us, there is no allegation of bad faith
against the Employer. At the time of the posting in October of
'1988 there were only. four.full-time employees at Store %58 who had
the requisite French language skills (Pilon, Pich~, Bussiere and
Chartier). The provision of French Language services during all
store hours is an operational requirement of a designated store.
While it may be appropriate to consider casual, and permanent part-
time employees for any such operational requirement, 'it' would
appear reasonable, we think, that the L.C.B.O. in assessing the
situation at the time of a vacancy would rely upon the number of
full-time staff to achieve the appropriate balance under the French
Lan~a~e Services Act.
The evidence of John Gerrard sati'~fies us that the equitable
scheduling of employees to provide French language services during
all hours of operation is a comple& task. Briefly stated, Mr.
Gerrard was unable to provide any schedule that would comply with
both the French Language service requirement and the provisions of
the collective agreement, in our view, the French Lan~uaqe
Serv%ces Act, 1986 provides an important context in assessing the
19
reasonableness of the French language qualification. Further, the
timing of the phasing in procedure during the second year (1988 as
opposed to 1989) is quite understandable given the significant
French speaking component in the City of Timmins, the existing
staff complement with French language skills, and the projected
date of implementation for Store #58 (November 18, 1988).
Accordingly, we must find that the French language qualification in
this posting is reasonably related to the position in question.
It is a truism that no competition when under intense scrutiny
can escape criticism. For example, it is difficult to understand
the rationale for the Employer seeking' the opinion of acting
Assistant Manager Marc Bus~iere regarding the need fo~ French
language skills when the Employer knew or ought to have known that
Mr. Bussiere would be an applicant for the job. Similarly, there
were three separate postings prepared for this particular
competition through a combination of errors which we were led to
believe, arose at head office. However, all applications for
ComDetition ~NR1-88 were duly considered.
If indeed the Employer was testing for a strong intermediate
level of French proficiency, that fact appears to have escaped the
attention of examiner Don Thibodeau. Similarly, there was no
reference to strong intermediate level in the job posting. On the
sensitive issue of French language qualifications, the Employer
would be well advised to clarify its expectations in future job
20
postings. However in the final analysis, it is an irrelevant
consideration given the evidence that the grievor failed to achieve
a mark at the .minimum level of intermediate French language
proficiency.
Inevitably, there will be some degree of subjectivity in marks
awarded for oral competency. However, the grievor's taped
conversational test was independently assessed by three experienced
evaluators. No evaluator found the grievor qualified even at the
minimum level of oral intermediate French language proficiency. On
the evidence adduced, we find that the grievor was fairly assessed
in accordance with provincial~' criteria for French language
evaluation.
Because of the impact of the French Lanquage Services Act,
1986, in ~hese particular circumstances, we cannot find that the
Employer violated the provisions of Article 21.5(a) of the
Collective Agreement. Similarly, we find no violation of the
Letter of Agreement, French Language Services.
By all accounts, George Ansara is a respected employee who has
a degree of French Language skill particularly'in the area of
comprehension. He was, of course, the senior applicant for the
position. Unfortunately, the evidence does not support.his claim
%hat he possesses the ability to speak French at the intermediate
proficiency level. For all of the above reasons, Mr. Ansara's
grievance and the Union policy grievance must be dismissed.
DATED at Brantford, Ontario, this "~Sth day of April, 1992.
R. L.. VERITY, Q.C. -VICEhCHAIRPERSON
"I Dissent" (dissent to follow)
J. McMANUS - MEMBER
~ 'DAUGH~TY~ .............