HomeMy WebLinkAbout1989-1282.McCarl.90-04-26 ONTARIO EMPLOYES DE LA COURONNE
"~ CROWN EMPLOYEES DE L 'ONTARIO
ORIEVANCE CQMMISSlON DE
SETTLEMENT REGLEMENT
, BOARD DES GRIEFS
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1282/89
IN THE HATTER OF AN ARBITRATION
Under
TEE CROWN EI~PLOYEES COLLECTIVE BARGAINING ACT
Befoce
TEE GRIEVANCE SETTLEMENT BOARD
BETWEEN:
OPSEU (McCarl)
Grievor
- an4 -
The Crown in Right of Ontario ('Ministry of Transportation)
Employer
BEFORE: S.L. Stewart Vice-Chairperson
M. Lyons Member
F. Collict Member
FOR THE H. [,aw
GRIEVOR: Grievance Officer
Onta_rio Public Service
Employees Union
FOR THE K. Cribbie
EMPLOYER: Staff Relations Advisor
Ministry of Transportation
HEARING: February 22, 1990
DECISION
Mr. R. McCarl was employed as a Patrol Operator B by
the Ministry of Transportation. The position falls within
the classification of Heavy Equipment Operator III. Mr.
McCarl worked out of the Stayner patrol yard which is
located in the Owen Sound district. He was discharged from
his employment due to the suspension of his driver's
licence. As well, he was denied a leave of absence for the
period of the licence suspension. Mr. McCarl has filed two
grievances, both dated September 20, 1989, in which he
grieves that his request for a leave of absence was
improperly denied and that his dismissal was without just
cause ·
The provision of the Collective Agreement relevant to
the request for the leave of absence is Article 29.1, which
provides as follows:
Leave-of-absence without pay and without the
accumulation of credits may be granted to an
employee by his Deputy Minister.
Section 18(2) of the Crown Employees Collective Bargaining
Act provides that employees covered by that legislation
will not be dismissed except for just cause.
A good deal of the evidence was not in dispute. Mr.
McCarl has been employed by the Ministry in the classified
service since October 26, 1986. He was considered to be a
good employee. Prior to his full-time employment, starting
in November, 1984, he performed work for the Ministry as a
seasonal employee. Prior to that time he worked operating
a sander for a private contractor who provided services to
the Ministry. Mr. McCarl is the father of three young
children. The family home is mortgaged. At the time of
his discharge his wife was employed outside of the home
only on a part-time basis.
Mr. McCarl testified that on a Friday evening in June,
1988, either June 9 or 14, he went to see a friend after
work to assist him with moving some material in his back
yard. Mr. McCarl stated that he consumed six or seven beer
in the process of carrying out this work and that he did
not have anything to eat. After finishing the work he
drove home in his own vehicle. He was stopped by a police
officer who asked him if he had been drinking. Mr. McCarl
testified that he advised the officer that he had been
drinking and that he complied with the officer's request to
accompany him to the police station. He provided a breath
sample which showed the level of alcohol to be 2.O. The
legal alcohol level is .08. Mr. McCarl was charged with
impaired driving.
The next morning, Mr. McCarl attempted to reach his
3
immediate supervisor to advise him of the matter but was
unable to contact him. He then contacted another member of
supervision and advised him of what had transpired.
Subsequently, Mr. McCarl entered a guilty plea to the
charge of impaired driving and was convicted of
that offence. He was fined $350.00 and his licence was
suspended for one year, commencing August 8, 1989.
The possession of a valid driver's licence is a
requirement of the grievor's position. When Mr. McCarl was
first hired he signed a document entitled "Conditions of
Employment Bargaining Unit Positions" which contains the
following with respect to the loss of a driver's licence:
Due to the nature of the Ministry's mandate, the
loss of your driver's licence will be viewed with
severity, if your duties require you to operate a
motor vehicle, whether the Ministry's or your own.
If any employee whose duties require possession of
a valid driver's licence has such a liCence suspended,
he/she must report the fact to his/her supervisor
immediately regardless of the circumstances under which
such suspension occured.
In certain cases, the suspension of his/her driver's
licence renders an employee immediately unable to
perform the duties of his/her position. In other
cases, however, alternative arrangements may be made
with no inconvenience, extra cost or loss of efficiency
to the Ministry.
You must realize, therefore, that if your licence is
suspended, termination of your services or demotion to
a position where operation of a motor vehicle is not
required, are possible consequences.
4
Mr. McCarl stated that he was familiar with the policy of
the Ministry. as outlined in this document. He also stated
that he was familiar with Ministry Directives C-31 and C-
32. Directive C-31 prohibits the use of drugs and alcohol
by employees while at work. Directive C-32 requires an
employee whose duties require the possession of a valid
driver's licence to notify a supervisor when his or her
licence has been suspended revoked or downgraded. As well,
Directive C-32 provides that where an employee's driver's
licence has been affected in this manner:
...non-disciplinary action is appropriate if the
employee is no longer qualified to perform all
or part of his/her duties.
When non-disciplinary action is indicated, among
the alternatives which may be examined are the
fol lowing:
(a) removal of the employee's driving responsibilities;
(b) removal of the employee's authorization to operate
any motor vehicle on Ministry business;
(c) reassignment of the employee (subject to
restrictions in the collective agreement, where
applicable );
(d) termination of employment.
Between the effective date of the suspension of his
licence, August 8, 1989, and September 5, 1989, when. he
ceased working for the Ministry as a result of his
dismissal, Mr. McCarl was assigned to miscellaneous duties
such as'maintenance, picking up litter and fixing signs.
5
On August 24, 1989, a meeting was held with the
grievor, his Union representative and three members of
management. One of the members of management present was
Ms. M. Majesky, District Engineer. It was Ms. Majesky who
made the decision that Mr. McCarl would not be granted a
leave of absence and who made the recommendation that his
employment be terminated. The minutes of that meeting and
Ms. Majesky's evidence established that she indicated to
Mr. McCarl that his actions were embarassing to the
Ministry in view of its involvement in campaigning against
impaired driving but that as it was his first offence, she
was inclined to treat the matter with some leniency. At
the meeting Ms. Majesky stated that the alternatives to be
considered were reassignment to a position that did not
require a driver's licence, Mr. McCarl's resignation, or,
his dismissal. Mr. McCarl was asked if he was experiencing
an alcohol problem which would benefit from an assistance
program. Mr. McCarl stated that he did not feel that he
did have a problem with alcohol. In his evidence before
this Board, Mr. McCarl confirmed this statement. Mr.
McCarl also stated in his evidence that he recognized that
what he had done was "stupid" and that he had exercised
poor judgement on this occasion by putting his family,
himself and his employment in jeopardy.
At the meeting, Ms. Majesky advised Mr. McCarl that
6
there were no positions available in the Stayner area and
that the position that could be made available to him was
on the electrical crew which worked out of Owen Sound.
Owen Sound is located some 45 to 50 miles away from Mr.
McCarl's home. It was stipulated that Mr. McCarl would
have to bear any expenses associated with the relocation.
As well, the position attracted a lesser salary. If Mr.
McCarl performed his work satisfactorily and there was no
indication of a problem with alcohol Mr. McCarl would be
reinstated to his former position upon reinstatement of his
licence, it was also noted in the minutes of the meeting
that Ms. Majesky indicated that: "the option of a leave of
absence is not available".
After the meeting, Ms. Majeskey sent Mr. McCarl a
letter dated August 25, 1989 wherein she confirmed the
three alternatives put forward to Mr. McCarl at the
meeting. Mr. McCarl replied to Ms. Majesky in a letter
dated September 5, 1989 wherein he stated that he did not
wish to accept the reassignment to the Owen Sound office
because of the cost involved. He further stated that he
wished: "to formally request a leave of absence without pay
until August 8, 1989." In his testimony before the Board,
Mr. McCarl explained that the cost involved in commuting to
Owen Sound and the expense that would be involved in
obtaining other accomodation in Owen Sound made the cost of
7
accepting the other position prohibitive. As well, he
would be away from his family. Mr. McCarl was able to
obtain other employment in the Stayner area, at a lower
wage than his previous employment. He stated that he
wished to return to his former ~osition.
Ms. Majesky replied to Mr. McCarl by letter dated
September 7, 1989. After reviewing the three options that
were put to the grievor at the August 24, 1989 meeting, Ms.
MaJesky states as follows=
In your letter of September 5, 1989 you indicated
you are not accepting reassignment to the electri-
cal crew. Your request for leave of absence with-
out pay is denied as it is against our Ministry
Policy. Therefore, I have no alternative but to
proceed with recommending your termination effective
September 5, 1989.
Ms. Majesky did recommend that Mr. McCarl be terminated
in a letter dated September 12, 1989 to Mr. J. Kernaghan,
Regional Municipal/Maintenance Engineer. In this letter,
Ms. Majesky provided a summary Of the events and the
proceedings and concluded as follows:
By way of letter dated Sept. 5, 1989, received
Sept 6, 1989, Mr. McCarl did not ~ccept the
reassignment and has requested a leave of
absence without pay.
As is documented in the summary of hearing, Mr.
McCarl was advised that a leave of absence was
not an option to be considered. The options
stated to him were as follows:
1) reassignment to a position with the Electrical
Crew which does not require a Driver's Licence;
2) dismissal from employment:
3} resignation.
In view of Mr. McCarl's rejection of the reassignment
option, I am recommending termination of his employment
from this Ministry, effective Sept. 5, 1989.
Ms. Majesky's recommendation was concurred with and was
ultimately accepted, resulting in Mr. McCarl's formal
termination.
Ms. Majesky testified that when she received the
request for a leave of absence she discussed the matter
with the Regional Director and his personnel responsible
for such issues. She stated that she was advised %hat
"they couldn't find any reason that we should grant him a
leave of absence". Ms. Majesky also stated that she was
also advised that: "it wouldn't be advisable to grant a
leave of absence under these circumstances" and that this
was her opinion as well. Ms. Majesky did not explain why
she felt that a leave of absence would not be advisable.
She did state that she did not wish to keep Mr.~ McCarl's
position open for him during a leave of absence because
there is minimum staffing on the crews and they need a
person, in the position. She stated that Mr. McCarl's
position has been filled for the winter by a contract
employee but that it was currently being advertised.
In cross-examination, Ms. Majesky was asked about her
9
statement in the September 5, 1989 letter that the granting
of a leave would be "against our Ministry Policy". She
acknowledged that there was no policy which specifically
prohibited a leave of absence being granted in such
circumstances and explained that what she meant was that
the policy of the Ministry did not specifically provide for
the granting of a leave of absence in such circumstances.
Ms. Majesky agreed with Mr. Law that the fact that the
incident of impaired driving took place while Mr. McCarl
was off duty made the incident less embarassing to the
Ministry than would be the case if the incident had taken
place when he was on duty.
On behalf of the Employer, Mr. Cribbie argued that
there was just cause for the discharge of Mr. McCarl and
that Mr. McCarl's request for a leave of' absence had been
denied in accordance with a proper exercise of the
Employer's discretion contemplated by Article 29.1. In
support of his position that the discharge was justified,
Mr. Cribbie referred to Jacobsen 394/82. In that case, the
Board upheld the discharge of an employee who was required
to have a driver's licence in order to perform his job but
had lost his driver's licence due to a conviction for
impaired driving. Mr. Cribbie emphasized that the Employer
had made the grievor aware of the fact that the possession
of a valid drivers licence was a condition of his
10
employment and the implications, including termination of
employment, 'that would flow from the loss of his licence.
Mr. Cribbie also emphasized that the Employer had found an
alternative position for Mr. McCarl and that Mr. McCarl had
declined this position. With respect to the request for
the leave of absence, Mr. Cribbie referred to the
principles set out in O'Brien 1157/86 and ¥oun__._.g 220/79 and
submitted that the decision making process was in
compliance with the relevant principles. Mr. Cribbie
argued that the issue of the leave of absence only became
relevant if it were concluded by this Board that just cause
for the discharge of Mr. McCarl had not been established.
On behalf of the Union, Mr. Law argued that the
decision to deny Mr. McCarl's request for a leave of
absence was not based on a proper exercise of discretion as
required under Article 29.1. In his submission, Ms.
Majesky did not put her mind to the merits of the request.
Mr. Law referred to the decisions of this Board in Kuyntjes
513/88 as setting out the appropriate standard of review of
the kind of decision that Article 29.1 contemplates. He
argued that this decision contains a more accurate and more
recent statement of the appropriate considerations than.
that set out in the Young decision. In his submission, the
decision of Ms. Majesky to deny the request for a leave of
absence was arbitrary in the same sense that the Board
11
found the manner in which the employer's discretion was
exercised in the O.'Brien case to be arbitrary. Mr. Law
also argued that the onus rests with the employer to
satisfy the Board that there were operational concerns that
justified its decision to deny the request to grant the
leave of absence and referred to a number of arbitration
decisions in the private 'sector in support of his position.
Mr. Law submitted that there was a balancing of interests
that must be undertaken in cases such as this and that
where the granting of a leave of absence was a reasonable
alternative available to the Employer, the discharge of Mr.
McCarl must be found to have been without just cause.
Clearly, the suspension of Mr. McCarl's licence made it
impossible for him to perform his regular duties. As well,
it is clear that Mr. McCarl was made fully aware of his
obligation to maintain a valid drivers licence and the
consequences, including termination, of his failure to do
so. Termination of employment is properly considered to be
the last step however, when other reasonable alternatives
have been exhausted. This was the approach taken in the
Jacobsen case referred to us by Mr. Cribbie. That case
involved a situation where the grievor had lost his licence
for a second time. The first time the employer was able to
find the grievor alternative employment but was unable to
find alternative employment for him after the second
12
suspension and terminated his employment. The Board found
that the employer had acted reasonably in so doing. There
was no request for a leave of absence in that case and
hence the considerations before that Board were somewhat
different than those before us. However, we agree with the
conclusion in that decision that the question to be
determined is whether the employer has acted reasonably in
terminating the employee. In this case, the issues of
whether there was just cause for the discharge of Mr.
'McCarl and whether his request for a leave of absence was
properly denied become intertwined. If a leave of absence
was a reasonable alternative that was improperly denied,
then it must be concluded that the employer's failure to
avail itself of this alternative and instead terminate Mr.
McCarl's employment, was not a reasonable action.
The decisions in ~, O'Brien and Kuntjes articulate
the considerations with respect to the manner in which the
employer's discretion is to be exercised in different ways.
We note, as Mr. Cribbie ~ointed out, that excerpts from the
decision in Young are referred to with approval in the
Kuntjes decision. The Youn~ decision sets out the relevant
considerations at p. 5, as follows [case references
omitted]:
The grievor is arguing that she has been unreasonably
denied leave of absence under Arictle 29.1. While
that article is framed in a way which appears to give
management an unlimited discretion in the granting or
13
denial of leaves of absence, in fact that discretion
must be exercised in a non-discriminatory and
reasonable manner, as many arbitration awards have
held. The employer, in deciding whether to grant or
deny a leave of absence, must consider the merits of
the individual application. He cannot rely on
"floodgates" arguments, saying that granting a leave
of absence in this case may lead to many more requests
and therefore set a dangerous precedent. Rather, the
employer must turn its mind to this particular request,
and consider both the harm to management's objectives
in granting the request and the importance of the
request to the employee and the hardship caused by the
denial.
An arbitration board, in subsequently assessing what
the en%01oyer has done in reaching its decision, then
plays a restricted role. It must decide whether the
employer has acted reasonably and without
discrimination and has turned its mind to the merits of
the particular request. If satisfied that these
criteria have been met, the Board must deny the
grievance, even if it disagrees with the result reached
by the employer or if it might have reached a decision
other than that reached by the employer. The Board's
concern is the reasonableness [emphasis in the
original] of the-decision, not its "correctness" in the
Board's view. Such an approach is the proper one to
adopt in situations such as leave of absence cases,
where the collective agreement gives the employer a
broad discretion and where the Board has less
familiarity than has the employer with the needs of the
workplace...
Even accepting the Mr. Cribbie's submission that the
Young decision properly sets out the scope of arbitral
review of a decision to deny a leave of absence in a case
such as this, after a careful review of the evidence, it is
our conclusion that the employer's discretion has not been
exercised in accordance with the principles outlined in
this decision. Prior to the time that the request for a
leave of absence was made, Ms. Majesky advised Mr. McCarl
14
that a leave of absence "was not an option". When she
received the formal request she took steps to determine
what the Ministry's policy was in such circumstances. She
determined that there was not a specific policy with
respect to granting leave in such instances The persons ·
advising her further stated that they could not think of a
reason that he should be granted a leave of absence and
that it would not be advisable to do so. Ms. Majesky
stated that she agreed that it would not be advisable to
grant the leave of absence.
Ms. Majesky's evidence does not, however, support the
conclusion that she put her mind to the merits of the
request and the competing considerations involved. Her
reference to the advice she received suggesting that "they
could not think of a reason" to grant the leave of absence
suggests that the grievor's interests were not assessed and
weighed in the decision making process. The denial of the
leave resulted in the termination of Mr. McCarl's
employment, the most serious of all possible consequences.
Clearly, there were interests of the grievor to be weighed
and assessed in light of any competing interests of the
employer. The evidence of Ms. Majesky supports the
conclusion that this assessment did not take place.
The only reason given by Ms. Majesky for her decision
to deny the leave of absence was that she did not wish to
hold Mr. McCarl's job open for him for a year. In view of
the employer's willingness to hold his job open for him if
he accepted another assignment, we cannot accept that this
is a reasonable basis for the employer to have denied the
leave of absence. The evidence did not disclose any
particular difficulty that would be created by holding the
position open, or, for that matter, any other difficulty
that would result from the granting of this request. The
process we are engaged in here is determining whether the
decision was a reasonable one, made after an assessment of
the competing interests; that is, a decision for which
there is some objective justification. The question is not
how this Board would have exercised its discretion. After
a careful assessment of the evidence, it is our judgment
the evidence does not support the conclusion that the
decision reached by the employer was a reasonable decision
that was reached after a weighing of all relevant
in format ion.
For these reasons, it is our conclusion that the
employer did not properly exercise the discretion conferred
by Article 29.1 of the Collective Agreement in rejecting
Mr. McCarl's request for a leave of absence. In view of
the basis upon which we reach this conclusion, there is no
need to address the argument raised by Mr. Law with respect
16
to onus of proof.
Mr. McCarl's employment was terminated because he did
not accept the relocation option offered to him and his
request for a leave of absence was denied. While the
Employer need not exhaust all possible options to ensure
the continued employment of a person in the situation of
Mr. McCarl, the Employer must act reasonably. Here, a
leave of absence was an objectively reasonable alternative
to discharge which the Employer rejected without reasonable
justification. Accordingly, it is our conclusion that the
termination of Mr. McCarl's employment was without just
cause.
We now turn to the question of remedy. After a
consideration of all relevant factors, it is our conclusion
that the appropriate remedy in this case is that Mr. McCarl
should be granted the leave of absence requested and it is
so ordered. He is to be reinstated %0 his former position
upon the expiry of the leave of absence, conditional upon
the reinstatement of his driver's licence. Mr. Cribbie
raised concerns about the possible displacement created by
the reinstatement of Mr. McCarl, however as this is an
academic matter at this point, this issue need not be
addressed. We retain jurisdiction in the event that there
are any difficulties in the implementation of this
17
decision.
Dated at Toronto, this 26 day of April, 1990
S. L. Stewar%- Vice-Chairperson
M. Lyon~,/- Member
F. Collic~ - Me~er
Dissent Re: G.S.B. #1282/89 (McCarl)
In this award it is concluded that the issues before the parties
can be decided as follows:
"If a leave of absence was a reasonable alternative that
was improperly denied, then it must be concluded that the
employer's failure to avail itself of this alternative
and instead terminate Mr. McCarl's employment, was not a
reasonable action."
(page 12 of award)
This Member cannot accept this conclusion.
Who is to determine that a leave of absence shall be given to an
employee who cannot fulfill the requirements of his job because of
a one year driver's licence suspension? Is it Management? Is it
a Board of Arbitration?
Management made its decision to deny the request for a leave of
absence inasmuch as it was deemed to be inappropriate relative to
the circumstances and in the context of the operation of Ministry
services. Was this an "improper" denial?
To accept the tenet or concept set out in the above excerpt at
page 12 of the award, it could readily follow that,
(a) a {eave of absence is a reasonable alternative for an employee
who is required to serve a one year jail term; or
(b) a leave of absence is a reasonable alternative for an employee
who does not like his job or is not progressing rapidly enough.
and who would like to try another employer for a year.
Moreover, at page 15 of the award, it is argued that,
"In view of the employer's willingness to hold kis job
open for him .......... we cannot accept that this is a
reasonable basis for the employer to have denied the
leave of absence. The evidence did not disclose any
particular difficulty that would be created by holdinq
the job open, or, for that matter, any other difficulty
that would result from the granting of this request".
However, the same rationale could be applied to the granting of a
leave of absence for the serving of a jail term or trying another
job With another employer. Is Management to be deemed
unreasonable for failure to grant these requests?
In the exercise of its discretion in this case, Management
assessed the circumstances and denied Mr. McCarl's request for a
one year leave of absence.
Is it the Board, then, that should decide whether a leave of
absence should be given to an employee who is unable to perform
his job because his license has been suspended for a year? In
Mailloux, G.S.B. #0087/88 at page 17, the Board stated the
following:
"The prospect of boards of arbitration striking down
management's decisions on the basis that an officer of
management failed to conduct a sufficiently thorough
investigation, asked himself or herself the wrong
question or misdirected himself or herself in some
material way to borrow the well-worn phraseology of
administrative law, risks converting a collective
agreement into an instrument for management by
arbitrators. In our view such broad powers of review
should not be found unless they are supported by the
clear terms of a collective agreement".
In the subject case, the provisions of Article 29.1 are very
clear. The discretion of the Deputy Minister is.unfettered; and
is not qualified in any way as in some collective agreements when
" such leave shall not be withheld
it may be stated that - ...
unreasonably " etc. etc
Essentially, and .as further stated in the Mailloux case (P. 17)
with reference to the "reasonableness" of manageme~t's decision,
"In a case such as this the legal or evidentiary burden
is upon the Union. It must establish, on the balance of
probabilities, that the Employer has failed to exercise
its discretion in a manner that is untainted by
arbitrariness bad faith or discrimination".
This Member agrees with the concepts cited in the award re the
Young decision on page 13. However, there was no evidence of
arbitrariness, bad faith or discrimination attributable to
Management with reference to Mr. McCarl. It was agreed that he
was a good employee. Nevertheless, Management deemed it
reasonable that a one year leave of absence should not be given to
him over the period that his licence was suspended and during
which period he could not perform the normal requirements of his
job.
Additionally the position of Management was eminently reasonable
based upon the evidence, as follows:
1. Rule C-32 (Exhibit 5 - P.4 of award) is clear. Mr. McCarl
acknowledged that he was aware of rule C-32;
2. Exhibit 14 sets out the position of the Ministry with
reference to matters associated with the loss of a driver's
licence;
3. Mr. McCarl agreed that he both knew of and had signed Exhibit
14. The form states.
"By signing this Form ADM-P-30, you confirm that you have
read and understood the above Conditions of Employment".
4. Management endeavoured to accommodate the circumstances of Mr.
McCarl (Exhibit 6);
5. Mr. McCarl declined and requested a leave of absence (Exhibit
7);
6. The request for leave of absence was declined (Exhibit 8).
Although not adduced in evidence or expressed in argument,
Management has the right to determine "complement" [C.E.C.B.A.
1 8( 1 ) ]; and hence there was no requirement on the part of
Management to carry additional staff; or to make additional
arrangements to accommodate Mr. McCarl; or to hold a position open
for him.
Certainly the alternative position offered to Mr. McCarl in Owen
Sound was not a palatable one for him; but how reasonable was his
decision to thrown away his total length of service with the
Ministry in the face of circumstances which he had caused? There
clearly was a financial and social penalty associated with the
offered position; but Mr. McCarl made the decision to decline.
Finally, Management has the right to establish rules, policies and
practice pertinent ko its operations. In this case where Ministry
vehicles are operated, a driver's licence is essential and this
fact is made abundantly clear to all employees, including the
alternatives in the event that the ~licence is lost.
Very clearly the language of Article 29.1~is discretionary. It is
agreed that it must be administered without discrimination, bad
faith and with reason. In the view of Management in this case, a
leave of absence for one year while awaiting~the termination of a
driver licence suspension was not a reasonable way to deal with
this matter. The decision, surely, is a decision which Management
has the right to make.
Absent bad faith, discrimination, arbitrariness and no clear
evidence of lack of reasonableness, the Board clearly exceeds its
jurisdiction in "second-guessing" or qualifying Management
decisions. The language of Article 29.1 is clear.
No evidence was produced to demonstrate that the denial of the
leave of absence was improper. The fact that a leave of absence
was a possibility to cover the one year licence suspension does
not make Management's decision unreasonable.
This Member would have dismissed the subject grievances.