HomeMy WebLinkAbout1989-1798.Fung & Anand.91-04-16. · -. ;~: ',..... ONTARIO EMPLOY£S DELA COURONNE
..' .~ . .: CROWN EMPL 0 YEE$ DE £ 'ON TA F~IO
GRIEVANCE COMMISSION DE
SE~LEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STRE~ WEST, SUITE 21~, TORONTO, ONTA~, ~G IZ8 ~ONE/TE~PHONE: (4~6J 326-r388
BE~EN
BEFOg: $. Stewa~ Vice-~ai~erson
J. Ca~thers M~er
FOR ~ ~.' ~and
Scott a A en '
Barriskers & Solicitors
EMP~YE~ Co~sel
Fraser & Beatty
Barristers
FOR THE : . P.. Thach~
THI~ ~TY Senior Assessor
. Minist~ of Revenue
HE~ING: . Janua~ 9, 10, 11, 1991.
INTERIM DECISION
There are two grievances before the Board in this
proceeding. Mr. Fung's grievance is dated November 21,
1989, and Mr. Anand's grievance is dated January 18, 1990.
Both Mr. Fuhg and Mr. Anand are employed by the Ministry of
RevenUe as property assessors. Their positions are
classified as Property Assessor 3. The grievors were both
unsuccessful applicants for two positions of senior
assessor for the City of Toronto assessment office which
is classified as Property Assessor 4. The successful
applicants were P. Thachuk and A, Lowry.. Both successful
applicants were notified of this proceeding and their right
to participate. Mr. Lowry elected not to attend the
Rearing. Mr. Thachuk 'attended and participated for part of
the hearing.
The Empl'oyer raised three pr'eliminary issues. The
Board heard evidence and argument with respect.to these
matters only. The first preliminary issue relates to %he
timeliness of Mr. Fung's grievance. The second issue is
whether the position of the Union discloses a fundamental
alteration to the nature of the grievances which should not
be allowed by the Board both because of the alleged change
itself a~d because of the nature of the ~'ichange, which was
characterized by the Employer as a "human rights" matter.
The third preliminary issue is whether the Union should be
2
prohibited from calling expert evidence dealing with
cultural bias in interviews. .~ .... . : 4.
In order to address these matters it is, appropriate
examine the text of the grievances..;. The text~of Mr..Fung's:
grievance states as follows: ~,~'. .'
statement of Grievance: - : ..... - -~..:.'~- .-: ,'~. ', ,
I grieve against management and in particular. Mr. S.
Stephen Regional Assessment Co~ssioner for violating
~ticle 4 of, the Coliective .Agre~ent;. and/also for
shying discriminato~ actions t~ards me.
Settl~ent Desired
(1) A written explanation as to why I was not included
in a "Post Job Filling Intervi~With/Mr~)cStephen'~'~
(2) Stop discr~inating against certain employees.
~ediately.
The tex~ of Mr. Anand's grievance states as foll~s:'
Stat~ent of Grievance
I grieve that the empl0y~r did not give me proper
consideration' for the P,A.4~Compe%,ition No.:,RE234-89,;
contra~ to the Collective Agre~ent.
8ettl~en% Desired
~at I be given the above position with full retroactivity
for sala~ and benefits.. ;- ,~ .. -
The Board heard evidence from Mr..-Anand and Mr,.j~,Stephen.
In addition,' the parties filed documentary evidence,with~,.~,'
the Board. There was no real dispute with respect to%theb
relevant facts.~ We will first address the facts .relevant
to the issue of the timeliness of Mr'. Anand,'_s grievance. Ld
3
Mr. Anand was notified that his application for the
position was unsuccessful in a letter dated November 16,
1989 from Mr. S. Stephen, Regional Assessment Commissioner.
While Mr. Anand was uncertain whether or not he received
the letter on November 16, 1989 it is apparent that he did
so as he was aware of the refusal when he wrote a letter to
Mr. W. J. Lettner, Assistant Deputy Minister, on November
· 16, 1989. In fact, it appears that Mr-. Anand must have
been advised informally that he was not a successful
applicant for ~his position as he refers' to becoming aware
of this matter on November 15, 1989 in"his November 16,
1989 letter. In the November 16, 1989 ..letter, Mr. Anand;
asks Mr. Lettner to review the decision denying him the
promotion. Mr. Anand sent a copy of this letter to Mr.
Stephen. Mr. Lettner replied to Mr. Anand by letter dated
December 22, 1989, advising him that he was satisfied'that
the competition had been conducted appropriately. Mr.
Anand testified that he was away on vacation and received
this letter on or about January 10, I990.
Mr. Anand submitted a grievance dated January 18, 1991,
to his supervisor, Mr. S. Mauntah. A stage one meeting was
held on January 22, 1990. No objection to the timeliness
of the grievance was raised at this meeting. Mr. Mantauh
replied by letter dated January 26, 1990. The text of Mr.
4
Mauntah's stage one reply is one ·sentence' which states:
"Upon further review and consideration of your Stage :1 .- '-
grievance dated January 18, 1990, your .grievance is h~r. eby·
denied". By letter dated February 9, 1990, the grievance
was referred to stage two by E. MacLean, a Union staff
representative. The referral to Stage two'was acknowledged
by Ms. L. Marston, Personnel .Administrator, in. a 1-etter~ :~
dated March 20, 1990 which also confirmed arrangements~,for.{.~-..~
the Stage two.meeting on March.. 27, 1990. The parties.had
agreed t° extend i~he.%imeiil~mits fo~ ~-the.-stage ~two~.~e_e~ing
because of scheduling· difficulties and this..'agreement.~was
confi~ed in writing in a letter dated March 8,,~.1990, :~from
~. Marston to. Ms.q.-MacLean~ ..~The..Stage ~two2' mee%ing(;~was{~h
'on March 27, 1990, as scheduled. .T~ere was no 'reference to
the grievance being un{~eiy~/~thestage,'"' two~me~%%ng'"~ ':~' "~' '~.~ By
letter dated April ~1.7, 19~. Mr. RusSell denied~,.th%n~-.. ~3 ~ ~
grievance and in ,that letter made reference to t.he~-.fact
that it was untimely. The·relevant portion· of this;.~let~er
states as f011~s:.. ~?.7¥j~ .~'-.~
I hav~ been assured that your experience and:
qualifications were fully considered by theA~ ] ~.
panel. Further, .in comparison to the successful.~
candidates, I ~ info,ed that they were found
t'o be superior to yourself in their ability
and qualifications to perfo~ the duties of the
.posted ~sition.
Accordingly, as.there has.been no violation of the
collective agre~ent,' your grievance is denied...
Additionaly, as your grievance was .not .filed:'in
accordance with the mandato~ t~e. li~ts~ontained
in Art.~27 of the Collective Agre~ent-~your grievance
5
is considered to be inarbitrable.
The grievance was referred to arbitration by letter dated
April 24, 199o. This grievance was consolidated for
hearing with the grievance of Mr. Fung'on agreement of
counsel.
The relevant provisions of the Collective Agreement are
the following:
27.1 It is the intent of this Agreement to adjust
as quickly as possible any complaints or
differences between the parties arising from
the interpretation, application, administration
or alleged contravention of thisAgreemen~,.~
including any question as to whether a matter
~. is arbitrable.
27.2.1 An employee who believe~ he has a complaint or
difference shall first discuss the complaint
or difference with his supervisor within
twenty (20) days of first becoming aware of
the complaint or difference, i
27.2.2 If any complaint or difference is not'
satisfactorily settled by the supervisor within
seven (7) days of the discussion it may be
processed within an additional ten (10) days
in the following manners
STAGE ONE
27.3.1 The employee may file a grievance in writing with
his supervisor. The supervisor shall give the
grievor his decision in writing within seven (7)
days of the submission of the grievance.
STAGE TWO
27.3.2 If the grievance is not resolved under Stage One,
the employee may submit the grievance to the
Deputy Minister or his designee within seven,(7)
days of the date that he received the decision
under Stage One. IN the event that no decision
in writing is received in accordance with the
specified time limits in Stage One, the grievor
may submit the grievance to the Deputy Minister .,
or his designee within seven (7) days of the date
that the. supervisor was required to give
decision in writing in accordance with Stage One.
27.3.3 The Deputy Minister or his designee shall 'h°ld a
meeting with the. employee within fifteen (15)
days of the specified time limit for receiving
the decision ..... · ..
27.13 Where a grievance is not processed within~
time allowed or has not been processed by the
employee or--the: Union Within the time~ pr. es~ri~e~:
it shall be de~ed to have been withdrawn.
27.14 In this'Article'j'days shall~include ali'-days ..... ~ ......
exclusive of Saturdays, Sundays. and .d~_%gna~9~:
27.15 The t~e li~ts "c6ntained in this~ Article my'be
~.~ e~ended:zb~agre~gn%.of~ the ~par=ies., ~n
27 16 The Grievance Settl~ent Board. shall, have.~no
jurisdiction to alter, change, ~end or enlarge
any..provi si9. of .~h~ qo l!ec~'ive. ~g~e~ U'f'~.9 b
It was co~n 'ground' ~hat the provisio'ns of
Collective~ Agre~ent cont~plate that the outside
l~itation for the fi g of a written grievance from the
t~e the grievance arises is thirty-seven days.
COnsidering the' exclusion of Saturdays, SundaYs and
holidays from ~.the calculation as prescribe~ by Article'
27.14 of the Collective Agre~ent ~t was forty-~wo ~aY~''
;-- - .' , , ~'
from ~he t~e Mr. Anan~ was focally advised that his
apglica~ion baa be~n unsuccessful ~o the t~e he filed
' '~
grievance. Accordingly, the grievance was five ~ays out
· · - ' ': ,
t~e. I% was also co~n '~round'an~, indeed,' well
7
established in the jurisprudence of the Grievance
Settlement Board, that the time limits under this
Collective Agreement are mandatory. However, it was Mr.
Anand's position that the Employer had waived its right to
object to the grievance on the basis of timeliness.
In support of his position Mr. Anand referred to a
number of arbitration awards from the private sector as~
well as two decisions of the Grievance Settlement Board:
Ministry of Correctional Services & OPSEU (Anderson)
1483/84 (Brent) and Ministry of Consumer and Corporate
Relations & OPSEU (Tharakan) 1978/88 (Kirkwood). The
Anderson decision, a decision of this'BOard pursuant to the
same provisions of the Collective Agreement relevant to
this case, dealt-with a situation where'd grievance was '~
forwarded to stage two of the grievance'_procedure outside
the prescribed~time limits. The employer referred to the
fact that the grievance was untimely but went on to address
the merits of the grievance. Notwithstanding the
provisions of Articles 27.13, 27.15 and 27.16 of the
Collective Agreement, the Board found that a grievance that
has not been processed in a timely manner is not deemed to
be withdrawn if it is established that reliance on these
provisions has been waived. At p. 5 of this decision the
Board refers to the following summary of the arbitral
jurisprudence at p. 210 of Collective Agreement Arbitration
8
in Canada (Palmer):
Like estoppel, "waiver is a .legal barrier to the .~ ~
exercise of the rights in a particular case, ~
erected by-.the conduct of [sic]__ words of the .,. .. :,.
parties". Conduct which has been held to amount to
a waiver inc.ludes: allowing a grievance .to. go through
the grievance procedure; failure to object at the first
opportunity in the grievance procedure; ·.. and an
attempt to settle the grievance. Waiver can als°. ~
by' verbal ,agreement.. The~ right to object at_a later_~
stage can be' retained by a statement to that effect at
the first, opportunity or~ by a timely objection,~ even.~: .~:~
though it was ,not raised, again until the hearing.
Generally, waiver arises therefore where ~t is clearly
indicated.~that one of.the parties does
invoke the procedural provisions of the collective
In tha~ case' the Bo d found that the Employer had
~ledge that the grievance had not been processed ~n
accordance with the t~e limit's p~escribed by the
Collective Agre~ent as it adverted to th~'t~e
res~nding to the grievance. Because of the fact that the.
~ployer ~roceeded..to c'onside~ the grievance on.~ its_ meri}~qx
the Board cOncluded that it had waived.its~obJec}ion._}o~
t~eliness. ' In reaching this conclusion the Board noted-,at,r.
p. 8 of its decision-that: -' ~
"... even though the onus is on the Union to es%ablish the
~iver, the onus is on .the Employer: to show that.it made.~, ~
its objection in a t~ely fashion". ...
In the Tharakan decision, supra, the grievance was. ~
fo~arded to the Grievance settl~ent Board for a ~eari~g
outside of the time limits prescribed for
9
the matter to arbitration. The Union referred the
grievance to arbitration requesting that it be consolidated
with another grievance. In a letter to the Grievance
Settlement Board, which was provide,~, to the Union, the
Employer objected to a consolidation of the grievances and
also Objected to the grievance on the grounds tha~ it was
untimely. The Union requested that the grievance be
scheduled for a hearing. The grievance was dealt with at
mediation and although the Employer raised the issue
timeliness with the mediator in the absence of the Union
the Union was not advised that the Employer was pursuing
this objection until the day before the hearing. The Board
Concluded that the timeliness objection had been waived.
· Its reasons for so doing are ~et out at pp. 4 and 5 as
follows ~
In the case before this Board, the defect was
apparent and the employer conveyed its objection
to the Registrar at its earliest opportunity, but
it did not convey its objection to the union directly
until the date before the hearing. By not saying
or communicating any objection to the union after the
employer' became aware that the grie%ance was being
processed for a hearing and then by participating in
the mediation process again without communicating its
objections to the union, the employer is acting in
such a manner as to take the hex= step and lead the
union to believe that there was no objection to the
arbitrability of this grievance. If the employer had
intended to resolve the merits of this case, without
waiving its rights to raise its objection, the
objection should have been raised Prior to the
media%ion and an agreement reached between the parties
that the mediation was occurring "without prejudice"
to the Ministry raising the time limit objection at
the hearing.
However, therefore as the employer failed to notify the'
Union as soon as the. employer~ found out that
grievance was being processed and by participating
the mediation again without making an objection;-the
Board finds that the employer waived the objection
the time limits which ~would 'otherwise have been
available to successfully argue that the Board had
no jurisdiction.
Mr. M~e~ argued that these'decisions, as-wei1 as
other cases from the~private Sector referred~to~by:'Mr;~,
~and, can be distinguished, from the facts of. this~ Sase.,
In particular, ~Mr% McKe~n emph~sized.the..referenCeS~.in~,th~
~derson and ~arakan' decisions-, to~ the Employe~-~giving3.d~
notice of the-fact th'at it,~,was relying~on.,its-.t~line~s, at~,S~l,f~.a
or just prio=, to the arbitration, hearing. ~It.-:was
s~tted that there.~was no 'detr~ental'~reliance.f.in~this~.~v
'instance. .~ ~ ~ ~ -.. - ......
.~ile Mr~ McKe~' is"correct~in'~inting out
evidence does not establish,, detr~entai, reliance~ on'
part of the Union or:.the~gri~vor it,is clea~.fr~%'h~
authorities referred fo .that it is not neces~a~7, for..~lc~
detrimental reliance'to be established in Order for~the.
doctrine of waiver to apply. Mr McKe~ also .emphasized.~c
that' factual matters and legal argents,. Such-as~:.
t~eliness 'objections, are fleshed out
grievance procedure. ~ile we agree in general with
pro~sition, the t~eliness.of Mr. Anand's grievance was~-
clear from the info~ation available to the EmplOyeroat~lthe=.?qo
11
time the grievance was filed. Whether or not the
timeliness of the grievance was adverted to, a party to the
grievance procedure must be presumed to be aware of the
facts relating to the timeliness of the 'grievance. As
stated in Town of Pembroke, 18 L.A.C. 125 (Johnston), a
party 'to a collective agreement in these circumstances is
"fixed with the knowledge of the timeliness of the
grievance".. While the facts of this case are not identical
to the facts of the Anderson and Tharakan cases, it is our..
view that the principle expressed in these cases tis
applicable.-. The principle that these cases establish is
that an objection based on non-c~mpliance with time limits~.
is' waived when there has been a failure to raise the
objection in a timely manner and the taking of a fresh step
prior to raising the objection. In the ~Circumstances of
this case, where the grievance was discussed at two
meetings on its merits, the grievance was denied in writing
on its merits following the stage one meeting and the
timeliness objection was not raised until the written reply
subsequent to the stage two meeting, it .is clear that a
timely objection to the failure to comply with the time
limits of the Collective Agreement was not made and that a
fresh step was taken prior to the timeliness objection
being raised. The fact that the objection was made prior
to the hearing or the eve of the hearing does not affect
the operation of the waiver. Once a timeliness objection
12
has been waived it 'cannot be revived by notice. For these,
reasons, .it is our conclusion that the EmplOYer's.. objections'?
to the arbitrability of Mr. Anand's grievance must fail.
The next iss~ue, is ~hether '~he Union is ~t.temPting< to~.TM
eXPand the-grievances in such a 'manner as to fundamentallY'
change the. nature of the original grie~vances. A 'related-~e~
issue is whether the "~an rights" issue ra~Sed~by
Union should~ not be dealt with by. this Board~ as''' it'~' is%~.{~
~tter more appropriately d~alt~ with iM~anothe~
~ese~issues ~y'be Understood in' the~':conte~ '~ '" of, the
~sitions'of .=he partiesras~7outlined- in~,theifSmS~ , ~ '
uo~res~ndence. By letter dated Dec~be~ 27~ 1990~'Mr%~·
~and wrote to>Mr~:McKe~ andtadvised'.h~ ~hat~,th'e
intended to lead e~ert~evid~nce at the ._he~ing& {o
establish' that:~ "oral'. intervi~s are inherehtl~abiased'~m
against persons whose first language is not English, and~nmu.{~cq~
whose customs and mannerisms ~y be in some ways
unconventional." Mr. 'Anand's letter went On to state:?,
will be our ~sition: that the Minist~ of Revenue
~properly placed undue emphasis on'the 0ral i'nte~vi~s~,'~3
conducted in the job competition..." . Mr.' McKe~n~''''' .'
res~nded, to this letter bx letter dated Janua~ 2;'
advising Mrs' Anand inter alia that he considered-this"to
an enlargement of the scope 6f 'the grievance and that~he~}°3J~.~.
13
objected to such an enlargement. Mr. Anand took issue with
this position in a letter to Mr. McKeown dated January 7,
1991.
Mr. Anand stated that the position of the Union in
regard ~o these two grievances is that th~e had been an
undue reliance on oral interviews in this competition which
constituted a critical defect in the selection process.
Further alleged procedural flaws are set OUt in a letter
date~ J~nuary 8, 1990 from Mr~ Anand to Mr. McKeown. The
remedy :hat is being sought by the Union is an order
directing that the competition be re-run with appropriate
safeguards. Mr. McKeown stated that prior to the. December
· 27, 1990 correspondence from Mr· Anand it was his
understanding that the issue raised by the grievances was
Simply whether the skills and qualifications of the
grievors are relatively equal to those of the successful
applicants.
While Mr.r Fung's grievance specifically alleges
"discriminatory actions" it was common'ground that this
particular reference was to the interview process which
took place subsequent to the communication to the
applicants of the results of the competition. It was also
common ground that Mr. Anand had advised Mr. McKeown that
the Union was not pursuing this particular allegation.
There was bri~k vi~a voce evidence called by the
parties with respe6t to .the n~ture of 'the'discussions ~that
took place-during the grievance Procedure. Mr. Anand .....
testified that "at 'the' stage one grievance meeting on
januarY 22, 1990, Mr;~ B'i Valentin'e, Union steward',' stated:
"Because of cultural differences and be'lng a' member of'a
minority, it' is~ hard'to s!ell the skills"' 'This statement~..~.'.
was recorded in Mr. Anand's notes of' the meeting.. · Thi~ .....
evidence was~ unchallenged...Mr.~. Stephen:'testified'~
allegation of discrimination hawsed' on cultur~al" or-
background Was raised at~ the- sec0nd' stage' grievance?;~o~:~'~
meeting. ,~'Also 'of~ relevances'to ~this'*issue ~'is~ a*
dated March 20, 1990 fr0m'Mr~ ~" Mancinf, the
~. Russell, i~n conffeCtion' with. the Anand grieva~ce%~'The~.s
relevant ~tion. 6f {his .memorand~' states~ ..... ~...' '~3v'{~
It has. been brought to my attention that an ~' %-~.
~ployee of the Migist~, Mr. Ru~nder Anand,
is alleging that h~ has been: discriminated against
on numerous occasions when competing for career
promotions within the Minist~. ' : -:~ :~ ~-~ ?
~e final document~ of relevance is Mr. Russell's second -~
stage reply of April 17, 1990 which states: '
I ~ info,ed that your complaint concerns your
unsuccessful application to competition RE-243/89.
Specifically, I understand your co~laint tO be -
that your experience and qualifications for th9.
. ~sition were not given proper considerati~
~ere was no evidence adduced with respect to what matters
were discussed in the grievance Pr~edure in connecti6W:
with the Fung grievance.
The decisions referred to us dealing with the
appropriate scope of the hearing before an arbitration
board address the appropriate balance between two competing
principles. The first principle is that it is the real
dispute between the parties that an arbitration board
should resolve and that it should do so, without undue
technicality with respect to the form and nature of the
grievance. The second principle is that it is
inappropriate to allow a party to arbitrate a matter that
is fundamentally different from. the matter that was-
processed through the grievance procedure in view of the
fact that the arbitration pro~ess is the las.t stage, of the
grievance procedure and that the grievance procedure exits
for the articulation and resolution of grievances. The
test has been articulated in Gwin and Liquor Control Board
of Ontario 27/83 (Draper) as whether the matter would~
"retain the essential identity of the o~iginal issues.. [or
whether there is] a request to entertain a grievance so
fundamentally altered as to be tantamount to a separate
grievance raising separate issues."
As is generally the case with such.grievances, both
Mr. Fung's and Mr. Anand's grievances are brief. While
these grievances do not make specific allegations with
respect to discrimination arising from reliance on oral
16
interviews, as the Board's .jurisprudence on competition. ."-' ~
cases attests, the allegation that an individual's
and qual-ifiCations have-not been fairly assessed becauB.e~.ofL~,~
an inappropriate reliance on oral'interviews is not an'~,. ~
unusual kind of .allegation to arise in such.g~rievances'.._~.~.-
Indeed, allegations of Procedural flaws commonly 'arise% i-n~,
grievances phrased in.language -similar to the .l~anguage.
the grievances before us'. '~ Un'like .the cird~mstances., in-
the decisions~ ~eferred.to. Us where the~Board .f.ound ~th'atl_thei
grievance, had. been eXpanded;~, we ca_nnot3~qonclude>.that3:t, his3~~
allegation"is~ one .tha.~ _c.0uid.: ngt ~e]-~ontempl'a_t..e.d~ bY.~._t~h.e~.ii~.~,~'
language..oft.the' grievance and. that~'what-: is.-brought- ~o.rwar~dz
to be. 1 itigated, at. arbitration. 'i s-~a~. ~.fundame.n_tal'iyd
~rievance'~. While it was agreed that the specific~.,~ ~. -~..~'
allegation.!gf~,,discrimination in Mr. Fung.,.s~ grievanC.el~;~ ·
related to the interview process?that, took place subsequent~.3~-~
to the hearing there, was no. evidence-adduced with r'esPeqt~.~
to the nature of the discussions that. took. 'place.
grievance procedure with respect to this grievance: ~It~ is
clear from the evidence adduded before the Board in ,
connection with the Anand grievance that at the first stage
meeting 'the Union' steward made the specific allegation that
cultural differences placed persons in a minority group.at
a disadvantage in "selling their skills". While the
allegation is more concisely articulated in Mr. Anand-'s..
letter of December 27, 1990 to Mr. McKeown, the allegation.;
17
was expressed in layperson's terms at the stage one
grievance meeting. From the March 20, 1989 memorandum from
Mr. Mancini it is apparent that the Employer was aware that
an allegation of discrimination was being made by Mr.
Anand. Clearly, the Employer was made aware that there was
an allegation of a disadvantage with respe6t to the
presentation of skills and qualifications because of
cultural differences arising from membership in a minority
group in the context of this competition. While it is
clear from..the-evidence that this particular-allegation was
not specifically addressed at the second stage meeting it
is our view that it would be inappropriate to require' that
all. allegati6ns-be' raised at all levels of the gr.ievance
procedure in order 'for such allegations tO be raised at the
hearing. Where the allegation is one that can fall within-
the general language of the grievance, where it' was raised
at the stage one meeting, where there was no specific
undertaking made subsequently in the grievance procedure
that the allegation was not being pursued and where counsel
for the Union advi'sed counsel for the Employer that this
matter was being pursued in advance of the hearing we
cannot conclude that the Union should be precluded from
raising this matter at the hearing.
The related issue is whether this Board should decline
to consider this allegation on the basis that it is an
18
issue that it is an allegati~on of discrimination that is
appropriately dealt with pursuant to the Human Right~ Code.
It was submitted'on 'behalf 'of the Employer. that it is:~_this
body which has the expertis, e.t6 deal With. such a ~t~er/'and
~that it would be inappropriate for the Grievance
~e Grievance Sentiment Board has ha~ the
to consider the.app=0Priate .approach~.t0 be t~en:.where
all~ations of % discr~n~tio~. 'co"tra~ ~- to the- H~h' ~ig~s~
~de are raised ~ before it'in ~ '~ber"of'-cases~-~ile?thf
Board ini~iallY~too~~-a more "expahsive ~Vi~-of th~'?.~u
-' approPriate~a~proach i~'Minist~, of Correctional'. Services ~'~
the Board's subs~uent jurisprudence has ~en a more
restrictive approach.. The.approach is s~rized in
Minist~ of Trans~rtation and Co~unications & OPSEU
(Beitner) (Roberts) 1841/87 at p. 8 as foll~s:
Generally, where a statute such as the Human Rights
Code provides a comprehensive sch~e for the investi
gation' and adjudication of complaints, the aggrieved
party is required to resort to that scheme' and cannot
enforce p~ely statu.to~ rights through labour
arbitration'. So, for ex~ple, where a statute p'lace'~
a positive obligation on one pargy to a collective
agre~ent and the collective agre~ent is silent
u~n the matter, an arbitrator will decline
jurisdiction in order to avoid' the spectre' of
re-writing a collective agre~ent which served in the
first place as the basis for his jurisdiction.
~so relevant to the facts of th~s case are the
~ard's further co~ents at' p~ 9: ? ~' : :
So insistent have arbitrators been that positive
obligations under a comprehensive statutory scheme
not be enforced at arbitration that they have
refused to permit the parties to "cloak" a naked
submission under a statute as a violation of a
general provision of a collective agreement, such
as a management rights clause, or some broad,
general practice. For example, in Re Aubin & Ministry
of Correctional Services 1044/87 (Gandz), the Board
rejected an attempt to use the overtime provisions
of articles 13.1 to 13.3 of the collective agreement
-- which merely set the overtime rate and specify when
overtime shall be paid -- to cloak a submission that
the Ministry discriminated against handicapped people
'in violation of Section 4 of the Ontario Human Rights
Code when it followed a practice of" removing an
'employee from the top of the overtime list when he
was placed on a long-term disability and putting
his name back on the bottom of the list when he
returned. After noting that the collective agreement
was silent on the question of allocation of overtime,
the Board said, "It may be that, indeed, this practice.'
contravenes the Human Rights Code. But the job of this
Board is not to rule on violations of the Human-.Rights
Code. The Code has its own enforcement mechanisms and
· these should be used to resolve complaints arising
under it" Id. at p.4
The Board goes on, in that decision, to outline the
circumstances in which arbitration boards do embark on a
consideration of the effect of a statute.
Can it be' said in the circumstances 0f this case that
the Union is asserting a "naked" or a "cloaked" statutory
claim of discrimination? It is our view that it cannot.
Article 4.3 of the Collective Agreement .irequires the
Employer to "give primary consideration "to qualifications
..
and' ability to perform the required duties". In spite of
the fact that there is no provision prohibiting
discrimination in the Collective Agreement under which
20
these grievances arise, the allegation t~at-the Employer
has failed to'give' the requisite consideration ~6 the ~-
qualifications and abil'itfes of the grievors 'becaUse'undue
reliance on an 'oral interview procesS'that di~Criminat~es
against the grievors because of-~their cultural and/o~r .
racial background deals with a substantive 'obligation umder
the Collective Agre~ent.~ Unlike the city--stances ~n~
cases relied °n~by t~ Employer, the ~Sition of the Uni°~
in this case~'is not c~ntingen~ on a'findi~g-of a viola~ioh
of the H~an Rights code.~ The all~ati~n~made '
~y also.give rise' to~ complaint under the H~an' Rights n % ~o
Code. However;.'.'as.~this Board 'has. n6ted ih Mi~i~t~of ~
Co~nity and; Social '~Services- a~4~:OPS~.?. (Union~- grievanceS' ' ) 9~..~'
1190/89 (S~ar~), =h~- fact that.there is concurrent?~ ~{~
jurisdiction with respectrto a ~tter, (in' that..case~.
whether an emplOYer, ~e reaSonable.provision~tfor.~'.%he3i
health and safety of ~ployees) arising both under a
statute and under a collective agre~ent, this fact does
not deprive the' Board of jurisdic{ion. We agree-
McKe~ that t~is decision is distinguishable from the. case
at hand as the decision dealt with s~lar Subst~ntive.~ ~
provisions under'a' statute"an~ a c°iiective agre~ent..' ~
However, if an allegation that is the subject of .a~..... '.~. ~.
statuto~ provision also relates directly to a substantiv~
provision' of a collective agre~ent, it is our vi~ t~t'''
this Board would be de~iining'to exercise its jurisdiction~.~.a~ .
21
· if it refused to consider the alleged violation of the
collective agreement merely because the~ matter is also the
subject of a statutory provision. The logical implication
of Mr. McKeown's argument is that if any ground of
discrimination prohibited by the Human Rights Code is
raised in connection with an alleged violation of a
substantive provision of the collective agreement the
matter should not be dealt with by the Grievance Settlement
Board. For example, if in a grievance alleging discharge
without just cause an employee alleged that the reason in
whole or in part for his discharge was his sexual
orientation, should-the Board refuse to..deal, with that
all'egation merely be.cause. such matter is a prohibite.d
ground· of discrimination under the Human Rights Code?
Clearly, the answer must be no. The Board would be
declining its jurisdiction if it were to take such an
approach ·
Mr. Anand suggested parenthetically :that this Board's
jurisprudence concerning an arbitration board's role with
respect to the interpretation of the Human Rights Code may
be in question in light of the more expansive approach
taken in Rothmans, Benson & Hed_ges Inc. (1990) 10 L.A.C.
(4th) 8 (Brown) which is based on an analysis of the
relevant judicial authorities. It is not necessary for us
to decide this issue. Even on what may .ibe characterized as
the restrictive jurisprudence of this Board,* we are
convinced that 'the effect of this jurisprudence is
Board should ~ot.c0nsider the particular allegation raised
in this case. As' Mr. McKeown suggested, the evidence may**.
be of a complex nature. However, it 'is certainly
unusual for this' Board to be called'u~n-tO assess do,lextel%,'
evidence. Wi'th respect to Mr. McKe~n'~s s~ssion
this ~tter should properly have been the subject of a
~li~ grievance' w'e note that it 'is co~n for ~is~ues'.~of~-.(,~-~
grievancesze*~he.' general ,significance 'of an/issue,_doesl, not~a
compel the ~onclusioni*that~the:~tter; is .*'not:~ properl~.~d'
the part of Mr. ~and .to*provide Mr. McKe~:wi%h
of the expert testimony, to be adduced by the Union. M~.
McKe~ referred to rule. 53~O3.'*of the Rule~ of
Proeedure which *obliges *a party who inten*ds to
expert witness at ~rial'to provide a re~rt'se~'ting
s~stance..o~ that person's evidence no' less than ten:days
prior to the c6~encement of the %riall Mr.. M~eo~
referred ~o Tomen v. O.T~F. (No.2) 11 :~.H.RiR. 13 (Ba~)',.
prelimina~ decisi:0n of a Board of Inqui~ under the. H~n~
~ghts Code which dealt with a number of procedural ~tters
prior to the co~encement of the, hearing of .%he merits in
23
case of some complexity in which there were a number of
parties. In that decision it was ruled that in the event
that any party wished to adduce expert evidence, a summary
of that testimony along with the identity of the expert and
that person's qualifications should be provided to the
other'parties two months prior to the commencement of the
next scheduled hearing date.
It was Mr. Anand's submission that this Board should be
reluctant to adopt and apply the procedural rules of. the
court system to arbitration proceedin'gs, particularly on a
piecemeal basis. Mr~ Anand noted that he had provided Mr.
McKeown with notice'of his intention to!.adduce expert..
evidence and the general nature of this evidence as a
courtesy in his letter of December 27, 1990 which was . ' ....
thirteen days in advance of the hearing date.
This matter became largely a theoretical issue however,
as the dates that were scheduled for the hearing of this
matter were taken up by the preliminary issues. As well,
Mr. Anand stated that he had no objection %o providing Mr.
McKeown with an expanded summary of the.expert evidence
that he intended to adduce. He stated further stated that
he made that undertaking on the assumption that such
disclosure would be reciprocated in the event that Mr.
McKeown intended to adduce expert evidence as well. We
24
have assumed that the expanded summary Mr. Anand undertook
"to provide includes the identity and qualifications of the
witnesses Mr. Anand intends to call and that this.
information will be provided forthwith. In light of Mr.
Anand's undertaking, it is our view that the Board'should
make no order with respect to this matter. We think that
in ~he particular circumstances of this case this matter is
appropriately left with counsel. In the unlikely event
that there is still an.outstanding issue with respect to
this matter when ~his hearing reconvenes the matter can be.
addressed at that time.
The hearing,is to reconvene on the dates previously
echeduled in accordance with these rulings.
Dated at Toronto, this l'6=~ay of April, 1991
S. L. Stewart - Vice-Chairperson
J. Carruthers - Member
D. Mont~TMOse - Member