HomeMy WebLinkAbout1992-2964.Fazakas et al.06-04-20
Crown Employees Commission de ~jj
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
"'Il..."
Suite 600 Bureau 600 Ontario
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GSB# 1992-2964
UNION# 93A037, 93A039
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Fazakas et al.) Union
- and -
The Crown in Right of Ontario
(Mini stry of the Attorney General) Employer
BEFORE Ken Petryshen Vice-Chair
FOR THE UNION Gavin Leeb
Barrister and Solicitor
FOR THE EMPLOYER Lucy McSweeney, Senior Counsel [May 9]
Meredith Brown, Counsel [July 28]
Ministry of Government Services
HEARING May 9 and July 28, 2005.
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Decision
Ms. S. Difederico, Ms. 1. Fazakas and Ms. L. Usselman, while unclassified employees
working at the Hamilton Courthouse, filed two sets of grievances in the early 1990s. One set
were job competition grievances and the other set concerned merit pay. Both sets of grievances
came before the Grievance Settlement Board ("the Board") for mediation on April 22, 2003.
The parties subsequently agreed to proceed separately with the two sets of grievances. At this
time, the only job competition grievances that have not been withdrawn are those filed by Ms.
Difederico. With respect to her job competition grievances and a termination grievance she filed
dated December 15, 1992, the Employer took the position that they should be dismissed for
undue delay. In a decision dated February 22, 2005, I determined that I would not dismiss these
grievances at that time for delay and that the Board would hear the merits of the grievances. The
hearing is continuing with respect to these grievances filed by Ms. Difederico.
This decision deals with the merit pay grievances of Ms. Difederico and Ms. Fazakas
filed on August 6, 1992. The Union withdrew the merit pay grievances filed by Ms. Usselman.
Ms. Fazakas, who became a classified employee on December 7, 1992, filed an identical merit
pay grievance in 1996 which does not add anything to the claim made in her earlier grievance.
Ms. Fazakas's grievance on merit pay filed in November of 1996 is both unnecessary and
untimely, and therefore is dismissed. The Employer did not take the position that the merit pay
grievances should be dismissed for undue delay.
Two issues arise from the merit pay grievances. The first is whether they should be
dismissed as untimely, as argued by the Employer. The second is what retroactive effect should
be given to these grievances in the circumstances. The factual context for these grievances was
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provided by an Agreed Statement of Facts, brief testimony from Ms. Difederico going to the
timeliness issue and some of the Board's decisions which addressed merit pay and retroactivity
during the relevant period.
In addition to setting out a part of the factual context, the Agreed Statement of Facts also
refers to the issues raised by the merit pay grievances. The substance of the Agreed Statement of
Facts reads as follows:
l. The Grievors, Ms. Jeannie Fazakas and Ms. Sylvia Difederico commenced their
employment with the Ministry of the Attorney General ("MAG"), at the Hamilton
Courthouse, in the position of Office & Systems Cashier and Clerk (OAG 6), on
December 5, 1988 and March 17, 1987, respectively.
2. Ms. Fazakas held the position of Office and Systems Cashier and Clerk, OAG 6, from
her date of hire in 1988 through to January 2004, with the exception of two acting
assignments as a Judge's Secretary (OAG 9) and Client Services Representative
(OAG 8). Her employment status changed from unclassified to classified on
December 7, 1992. Ms. Fazakas is currently employed at the Hamilton Courthouse as
a Client Services Representative, OAG 8.
3. Ms. Difederico's employment with the Ministry was terminated January 17, 1993.
On April 25, 1994, she was rehired as a Court Services Officer (Usher and
Messenger). She is currently employed at the Hamilton Courthouse and holds
contracts as a Court Records Clerk (OAG 6) and Court Services Officer (Usher and
Messenger). Her employment status remains unclassified.
4. On February 5, 1991, the Grievance Settlement Board (GSB) released a decision
called Williams Barber in which unclassified correctional officers grieved that they
did not receive merit pay while unclassified, despite the fact that they worked
continuously for the Ministry and improved in skill and ability in the same manner as
their classified colleagues (who did receive merit). The GSB agreed, and ruled that
under the collective agreement the grievors' unclassified service should count for the
purpose of merit pay.
5. The Williams Barber decision was judicially reviewed by the employer. The
Divisional Court dismissed the employer's application on March 18, 1992 and upheld
the GSB decision.
6. MAG reviewed the Williams Barber decision and drafted a policy to implement the
decision within the Ministry. The policy, called "Merit Increases for Unclassified
Staff' ["the Policy"] was implemented in May 1992, and provided that unclassified
employees (including the Grievors) would receive merit raises on their next contract
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renewal date. Since that time, per the Policy, the Ministry has given merit raises to
unclassified staff who otherwise meet the criteria for merit.
7. Prior to the implementation of the Policy, it was the practice of the Ministry's Court
Services Division not to award merit increases to unclassified staff. At that time
unclassified staff, such as the Grievors, received only cost of living increases and any
other negotiated pay adjustments.
8. OPSEU did not file a policy or other union grievance, with respect to the Merit
Increases for Unclassified Staff policy.
9. In August 1992, Ms. Fazakas, Ms. Difederico and Ms. Lynn Usselman (Johnston)
filed grievances alleging that they had not been paid at the proper wage progression
levels after working the equivalent of one full year. They sought a remedy retroactive
to one year after their initial date of hire.
10. The Grievors were advised in writing on August 13, 1992, that the Employer objected
to the timeliness of their grievances, as the change in Ministry policy re: merit
increases to unclassified staff was implemented in May 1992, and they did not file
their grievances until August 6, 1992.
11. In November 1996, Ms. Fazakas and Ms. Usselman (Johnston) filed additional
grievances alleging a similar violation of the collective agreement, namely that they
had not been paid at the proper wage progression retroactive to their initial date of
hire.
12. Both grievances of Ms. Usselman (Johnston) have been withdrawn by OPSEU The
two grievances of Ms. Fazakas and the one grievance of Ms. Difederico are still in
dispute.
13. Both Grievors seek a remedy which would award them merit raises for the period
between the anniversary of their date of hire and the implementation of the Ministry's
change in policy in May 1992.
14. The parties ultimately negotiated a change to the language in the MBC-OPSEU
collective agreement to clarify that unclassified staff were entitled to merit raises.
This change did not appear in the January 1, 1992-December 31, 1993 collective
agreement. The changed language was first negotiated in the January 1, 1994-
December 31, 1998 collective agreement and stated in Article 31.2.2 that: "A full-
time unclassified employee coved by Article 31 [terms of employment for
unclassified employees] shall be entitled to the same provisions regarding progression
through the salary range and retroactivity of salary revisions as those agreed upon for
the Bargaining Unit to which they correspond."
In order to appreciate counsels' submissions, it is useful to review the facts in the context
of the results of some of the decisions which addressed the merit pay issue. It is evident from the
5
decisions referred to by counsel that the issue of merit pay for unclassified employees first arose
in the early 1990s in the Ministry of Correctional Services ("the MCS"). The general practice in
the MCS was not to give merit increases to unclassified employees. Mr. D. Williams challenged
this practice in a grievance filed in May of 1990 in which he claimed entitlement to a retroactive
merit increase back to August 21, 1987. The Board heard his grievance and the grievances of
five other Correctional Officers ("COs") in early January of 1991. In a majority decision dated
February 5, 1991, the Board determined that the grievors were entitled to merit pay and that they
should have been paid at the CO 1 second level after working the equivalent of one full year as a
C01. See, Williams Barber et aI., GSB 1448/90, 1449/90 and 1466/90 (Samuels). The
Divisional Court dismissed an application for judicial review of Williams Barber in a brief
endorsement on March 18, 1992. The Court simply indicated that the Board's interpretation of
article 3.3.1 of the Collective Agreement was not patently unreasonable. On August 4, 1992,
approximately five months after the Court's decision, the MCS introduced a Merit Increase
Policy for Unclassified Staff ("the MCS Policy"), which became effective July 1, 1992.
Many grievances were filed in the MCS on the merit pay issue. Indeed, there were in
excess of eight hundred such grievances, some before the Divisional Court decision and many
after. One of the grievances was a Union grievance dated June 18, 1992, claiming that the
Employer failed to pay appropriate merit increases to COso These grievances were before the
Board in Hammond Maier, GSB 2426/90 and 2723/91 (Finley) where the Union sought relief
from what was referred to as the 20-day retroactivity rule. Under the grievance procedure, an
employee was obliged to discuss a complaint with his supervisor within 20 days of first
becoming aware of the complaint. After reviewing a number of decisions and responding to
some general questions from the parties, the Board, in a decision dated March 3, 1994,
determined that the date for assessing retroactivity was March 18, 1992, the date of the
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Divisional Court decision. Retroactivity for grievances filed after this date would be based on
March 18, 1992, and the 20-day rule would apply to grievances filed prior to that date. Given
the number of grievances, the Board indicated that it attempted to reach a practical balance
within the context of the Board's jurisprudence. This decision was judicially reviewed, and
upheld on March 24, 1995.
In Re OP SEU (Union) and Ministry of Solicitor General and Correctional Services, GSB
2520/94 (Kaplan), the Board was asked to decide whether the Hammond Maier decisions (there
was a subsequent decision dated March 11, 1996) applied to individual employees of the
Ministry who did not file a merit pay grievance by March 3, 1994, the date of the first
Hammond Maier decision. In its April 16, 1997 decision, the Board noted that the
Hammond Maier award addressed the issue of retroactivity, but not coverage. Based the Union
grievance dated June 18, 1992, the Board determined that eligible non-grievors were entitled to
the same retroactive date as awarded to grievors in HammondMaier.
One other decision which dealt with grievances about merit pay in the MCS is Re
OPSEU (Elliott et al) and Ministry of Correctional Services, GSB 926/92 and 1335/93 (Finley).
I refer to it at this point for completeness and I will comment on it in more detail later in this
decision.
The Ministry of the Attorney General ("MAG" or "the Employer") also had a practice in
its Court Services Division of not paying merit increases to unclassified staff. In contrast to the
grievance activity on the merit pay issue in the MCS, it appears that Ms. Difederico, Ms. Fazakas
and Ms. Usselman were the only employees in the MAG that grieved about merit pay, and they
did so approximately 411z months after the Divisional Court decision in Williams Barber. Unlike
7
what occurred in the MCS, the Union did not file a policy grievance against the MAG
concerning a failure to pay merit pay to unclassified employees.
It is likely that the MAG became aware of the merit pay issue subsequent to the release of
Williams Barber. There is a reference in a MAG debriefing note dated October 15, 1991, that
the MAG decided to adopt a practice of paying merit increases to unclassified staff. The policy
was not implemented until May 26, 1992, some 211z months after the Divisional Court decision in
Williams Barber. The Merit Increase for Unclassified Staff Policy ("the MAG Policy") provided
that unclassified employees would receive merit increases on their next contract renewal date.
Given that unclassified contracts were renewed generally in April of each year, this meant that
unclassified employees in the MAG would not receive any merit increases until April of 1993.
Ms. Difederico was unaware of the MAG Policy when she filed her merit pay grievance
on August 6, 1992. While dealing with the issue of job competitions in August of 1992 with
Union representative Ms. B. Marshall, the subject of merit increases was discussed. Ms.
Marshall advised Ms. Difederico, Ms. Fazakas and Ms. Usselman that they should have been
receiving merit increases because they worked full-time hours with no break in service. Up until
then, Ms. Difederico was not aware that she was entitled to merit pay. Within a day or two
after their discussion with Ms. Marshall, the three employees filed their merit pay grievances. In
denying the grievances, the Employer took the position that the grievances were not timely
because the MAG Policy had been implemented months earlier.
I first turn to the issue of whether the grievances before me are timely. The Union takes
the position that they are timely for essentially two reasons. It argues that the 20-day time limit
under article 27.2.1 of the Collective Agreement does not start to run until an employee
8
subjectively believes that he or she has a complaint that could be a violation of the agreement.
Counsel submitted that the grievors were unaware that they had a complaint about merit pay and
did not appreciate that there was a contravention of the Collective Agreement until their
discussion with Ms. Marshall. He noted that they grieved within two days of their discussion
with Ms. Marshall. The Union also argues that merit pay is a matter of a continuing nature,
making a grievance timely if filed within 20 days of an employee being paid. In support of these
submissions the Union referred me to Re OPSEU (Pierre) andMinistlY of Correctional Services,
GSB 0492/86 (Verity), Re OP SEU (Clerk 6 General) and Management Board of Cabinet, GSB
564/82 (Kennedy) and Re Religious Hospitaillers of St. Joseph of Hotel Dieu of Kingston and
OPSEU (1992),29 L.AC. (4th) 326 (Stewart).
Counsel for the Employer noted that the MAG policy was in effect when the grievances
were filed in August of 1992 and that for many years neither the grievors, nor anyone else in the
MAG for that matter, had raised an issue about merit pay. Counsel submitted that this situation
could not be salvaged by the submission that the grievances were of a continuing nature.
Counsel also argued that the individual awareness test should not be applied in circumstances
where the Union was aware of an ongoing issue for some time and did not advise its members.
In counsel's submission, the timeless issue should be linked to the Union's knowledge. Counsel
also noted that Ms. Fazakas did not testify and we therefore do not know when she became
aware of the right to complain about merit pay.
The grievance procedure in the 1992-1993 Collective Agreement is in article 27. The
relevant part of this article is 27.2.1, which provides as follows:
An employee who believes 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.
9
InRe OPSEU (Pierre) , supra, Ms. Pierre filed her grievance on March 4,1986, after she
became aware of her right to do so from speaking with the Chief Steward on February 25, 1986.
The events giving rise to her grievance occurred no later than November of 1985. In addressing
the timeliness issue, the Board commented as follows at page 14 about what is necessary to
comply with the time limit:
What is required on the part of the employee to comply with the mandatory 20 day time
limit, is knowledge or awareness that there has been a violation or a possible violation of
the provisions of the Collective Agreement. Article 27.2.1 contemplates the knowledge
on the part of the employee - a subjective concept.
In finding the grievance timely, the Board determined that".. .the date the grievor learned of the
events or circumstances giving rise to her grievance (whether in February or November, 1985) is
not the determining factor. The Board finds as a fact that prior to February 25, 1986 the grievor
had neither the knowledge nor the belief that her concerns were amenable to resolution under the
Collective Agreement." The Pierre decision was upheld on judicial review. In its endorsement
dated July 11, 1990, the Divisional Court wrote, "The words 'believes' and 'becoming aware'
found in Article 27.2.1 clearly establish that it is only the subjective awareness of the employee
that she has a complaint arising out of a possible violation of the agreement that sets the 20-day
time limit running."
The Employer's timeliness objection focuses on the filing of the grievances in relation to
the introduction of the MAG Policy. However, Ms. Difederico did not file her merit pay
grievance against the MAG Policy because she was not aware of this policy. In any event, Ms.
Difederico did not have a subjective awareness that she had a complaint about merit pay and she
did not understand that there was a possible violation of the Collective Agreement until she
spoke with Ms. Marshall in August of 1992. Although she did not testify, I am prepared to infer
10
from the evidence that Ms. Fazakas was in the same position in this regard as Ms. Difederico.
Ms. Fazakas participated in the discussion with Ms. Marshall and both grievors filed their
grievances soon after that discussion. The application of the Pierre test to these circumstances
leads to the conclusion that the grievances were filed within the time limit prescribed by article
27.2.1. In my view, the knowledge of the Union is irrelevant when determining whether an
individual grievance is timely because the words in article 27.2.1 make clear that it is the
employee's belief that it critical, not the Union's. In these circumstances, it would be wrong to
impute the Union's knowledge to the employee. Although unnecessary, I would also find that
the grievances are timely because they are continuing grievances.
I turn now to the issue of what is the proper retroactivity date for these grievances.
During the course of the thorough submissions of counsel, I was referred to many decisions,
mostly GSB decisions, which deal with the issue of retroactivity. Many of them refer to the 20-
day retroactivity rule. For example, inRe Smith, GSB 237/81 (Roberts), dated March 5,1985,
the Board made the following comments about the rule:
The usual rule is that, barring the existence of circumstances which would make
it inequitable for the Ministry to rely upon it, retroactivity will be limited to the period of
time within which it was permissible for the grievor to file his grievance. In the case of
this Collective Agreement, that period is 20 days prior to the day upon which the
grievance was actually filed. See Re OP SEU and Ministry of the Attorney-General,
G.S.B. 71/76, in which the Board stated:
"While it is, in our view, clear that the employer failed to comply with the
provisions of Article 10.3 throughout the period from January 18, 1976, we do not
believe that these employees who initiated their complaint only on May 25, 1976,
may properly claim relief throughout that period. To the contrary, and to hold
otherwise, would be to improperly penalize the employer for the breach of an
agreement of which it was not aware. Thus, where as here, the breach of the
agreement is in the nature of a continuing one, boards of arbitration have
consistently limited an employee's right to claim damages for the breach of the
agreement to the period of time within which it was permissible to file his
grievance. Re: Union Gas Co. of Canada Ltd (1972),21 L.AC. (2d) 45
(Weatherill). Re: Automatic Screw Machine Products Ltd (1972),23 L.AC. 396
11
(Johnston). Re: National Auto Radiative Manufacturing Co. (1967), 18 L.AC.
326 (Palmer)."
(emphasis added in original)
The primary issue to be determined in this case is whether it would be inequitable to limit
relief to a period of 20 days before Ms. Fazakas and Ms. Difederico filed their grievances. The
Union takes the position that the remedy should extend back to the time when the grievors first
would have been entitled to receive merit pay. For Ms. Difederico this would be before the end
of 1987 and for Ms. Fazakas it would be the middle of 1989. Alternatively, the Union argued
that retroactivity should go back to March 18, 1992, the date selected in Hammond Maier. The
Employer takes the position that the grievors are not entitled to any relief in the circumstances
and that, in effect, the Board should endorse the MAG Policy. In the alternative, the Employer
argued that any remedy should not go back beyond the 20 days before the grievors filed their
gnevances.
In arguing that full retroactivity was appropriate in this case, counsel for the Union
emphasized that there is no dispute that the grievors were entitled to merit pay. He submitted
that when balancing the interests of the grievors, who had been deprived wrongly of merit pay
for a number of years, and the Employer who has contravened the Collective Agreement, the
Board should favour the grievors. Counsel argued that the fact that the Employer had no
knowledge of a claim until the grievances were filed is irrelevant and that the grievors are merely
seeking payment now of monies that the Employer has saved over the years. Counsel also relied
on the maxim that where there has been a wrong, there must be an appropriate remedy.
Counsel also argued that there is a direct relationship between the right to grieve where
an employee has been unaware of a violation of the Collective Agreement and the appropriate
12
remedial period. In other words, the lack of awareness of a violation by an employee gives rise
to an entitlement to full retroactivity. Counsel noted that although the decisions on retroactivity
do not specifically rely on this rationale, the rationale underlies the results in some of the
decisions. Counsel referred in particular to Re Williams Barber, supra, Re OPSEU (Pierre),
supra, and Re OPSEU (Clerk 6 General) and Management Board of Cabinet, supra.
Counsel placed considerable reliance on Williams Barber, a case in which full
retroactivity was given and which was upheld on judicial review. Counsel submitted that any
subsequent decisions that depart from Williams Barber are wrong in law. In this regard, counsel
referred to Re Blake et ai, GSB 1276/87, in which the then Chair, in effect, indicated that a panel
of the Board should follow the decision of another panel unless there are exceptional
circumstances which justify not doing so.
With respect to the Union's alternative position, counsel argued that certain features of
this case warranted the conclusion that the date of March 18, 1992 is the appropriate retroactivity
date for the grievors. He noted that it is evident from the debriefing note that the MAG had
knowledge of the merit pay issue and that it had decided to change its practice in October of
1991, yet it waited for seven months before it implemented the MAG Policy. Counsel suggested
that implementation of the MAG Policy was skilfully timed to ensure that unclassified
employees in the MAG did not receive merit pay until April of 1993. Counsel argued, as well,
that the Divisional Court decision in Williams Barber finally resolved the issue of merit pay for
the government and noted that because of Vice-Chair Kaplan's decision in Re OPSEU (Union),
supra, even non-grievors in MCS were given retroactivity to March 18, 1992. Counsel argued
that in these circumstances the grievors should at least receive retroactivity back to March 18,
1992.
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In addition to the decisions referred to previously, counsel for the Union relied on the
following decisions: Re OPSEU (TGndenheuvel et al) andMinistry of the Environment, GSB
2086/91 (Low), Re OPSEU (Cameron) and Ministry of Correctional Services, GSB 2174/87
(Draper), United Food and Commercial Workers Union Local 280P v. Pride of Alberta Meat
Processors Co. (c.o.b. Gainers), [1998] AJ. No. 466 (Alberta C.A), Re Leisure World Nursing
Homes Ltd, North Bay and Service Employees Union, Local 478 (1983), 12 L.AC. (3rd) 345
(Langille), Re OPSEU (Kimmel Leaf) and Ministry of Government Services, GSB 1391/90
(Kaplan), OPSEU v. Ontario (Ministry of Community and Social Services), [1986] OJ. No. 152
(Div. Ct.) andRe OPSEU (Cleveland) and Ministry of Correctional Services, GSB 2350/92
Stewart).
Counsel for the Employer argued that there are no exceptional circumstances
present in this case which would justify departing from the application of the well-entrenched
20-day rule. She submitted that there is no basis for giving retroactivity for a period of time
when the employees in the MAG, including the grievors, the Union and the Employer did not
believe that there was an issue about merit pay.
Counsel submitted that the purpose of the 20-day rule is to prevent a remedy going back
for a period of time when an employer is unaware of a challenge to the way it administers the
collective agreement. Counsel argued that the rule prevents an employer from being penalized
when it has not been given the opportunity to address a possible contravention of the collective
agreement. Counsel submitted that there are limited exceptions to the rule and that they arise
primarily because it would be inequitable to apply the rule due to an employer's conduct.
Counsel submitted that there is no valid reason for linking a right to retroactivity to an
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employee's awareness of a violation. Apart from the absence of arbitral support for this
approach, counsel submitted that what is critical is the making of a claim against an employer
and not the fact that a claim had not been made earlier because an employee was unaware of a
violation. In counsel's view, an employee awareness test does take into account that an
employer would be penalized for a time when it was unaware of a potential violation. Counsel
also maintained that what took place in the MCS was irrelevant for determining a retroactivity
date for these grievors, since the focus must be on what was occurring in the MAG.
Contrary to the Union's submission, counsel argued that Williams Barber should
not be followed. Counsel noted that the majority in that case did not specifically deal with
retroactivity or the 20-day rule. She also argued that the result in that case is inconsistent with
the general thrust of the arbitral jurisprudence. Counsel submitted that the Board should
conclude that the MAG Policy, with its prospective feature, was an appropriate response in the
circumstances and dismiss the grievances. Alternatively, if any remedy is warranted, counsel
argued that only the application of the 20-day rule would be appropriate.
In addition to cases referred to previously, counsel relied on the following decisions: Re
OPSEU (Burrows) and Ministry of Labour, GSB 0379/88 (Mitchnick), Re OPSEU (Ababio et al)
and Ministry of Revenue, GSB 1295/88 (Watters), Re OPSEU (Hillman) andMinistry of
Transportation, GSB 2007/89 (Kaplan), Re OPSEU (Hadwen et al) Ministry of Revenue, GSB
284/89 (Gorsky), Re OPSEU (Kay, Milak, McCauley Truchon et al) andMinistlY of
Transportation, GSB 93/88 (Barrett), Re OPSEU (Letourneau) and Ministry of Correctional
Services, GSB 1158/92 (Stewart), Re OPSEU (Union Grievance) and MinistlY of Solicitor
General and Correctional Services, GSB 2520/94 (Kaplan) and Re OPSEU (Clapperton et al)
and Ministry of Solicitor General and Correctional Services, GSB 0410/97 (Petryshen).
15
Having regard to the submissions and the facts in this case, it is my conclusion that it is
appropriate to apply the 20-day retroactivity rule. This rule has been a feature of the GSB' s
jurisprudence for many years. The Union's submissions which focused on how to balance the
interests of the grievors and the Employer in this instance appear to be arguments for abandoning
the rule altogether. The rule was developed and has been applied in order to provide for such a
balancing of interests. Although the rule has exceptions, the case law does not suggest that an
employee's lack of awareness of a violation of the collective agreement creates an exception to
the rule. In my view, although relevant to the timeliness of a grievance, an employee's
awareness of a violation is not a relevant consideration when deciding whether retroactivity is
appropriate. Timeliness and retroactivity are distinct issues. Since it is likely that grievances are
filed when an employee or a union becomes aware of a violation, there would be no need for the
20-day rule if the employee awareness test the Union proposes were adopted.
I agree with the submission of counsel for the Employer that Williams Barber and the
Divisional Court decision are not particularly helpful precedents on the retroactivity issue. The
reasons of the majority in Williams Barber and the Divisional Court endorsement do not refer to
the 20-day rule and they do not explain why full retroactivity was appropriate. I prefer to follow
those decisions which specifically address the issue of retroactivity and these decisions rarely
award full retroactivity.
The Union's alternative position in particular raises questions about the significance of an
employer's knowledge of a violation and the relevance of events which occur in another
Ministry. Knowledge on the part of an employer about a possible violation is a consideration. In
my view, however, the employer must be aware that there is a claim being made relating to its
16
administration of the collective agreement. The fact that a decision has been made by the GSB
on grievances in another Ministry is not, by itself, determinative of a retroactivity issue.
Support for the preceding analysis can be found in two decisions that, in my view, are
particularly helpful. These decisions address some of the Union's submissions and they provide
an appropriate framework for dealing with retroactivity. Re OPSEU (Elliott et al), supra, is a
retroactivity decision dealing with merit pay for unclassified staff at the Sault St. Marie Jail. The
grievances had not been included in the many grievances that were before the Board in
Hammond Maier. Mr. Bishop, President of the Local Union, filed a policy grievance dated
January 18, 1992, when he was alerted to certain wage discrepancies when dealing with other
grievances. He was unaware of Williams Barber when he filed the policy grievance and he did
not discuss the grievance with affected employees. He subsequently told employees about the
policy grievance when he advised twelve COs to file individual grievances, which they did on
April 20, 1992. The twelve grievors were unaware of a merit pay issue prior to their discussion
with Mr. Bishop. They did not know that there were two levels in the COl pay scale and that
they had a right to grieve merit pay. The grievors had been hired as unclassified COs between
1987 and 1990. The Union demonstrated that COs at other institutions with less service reached
the second level of the CO 1 classification earlier and therefore were being paid more than the
gnevors.
The Board in that case referred to a number of retroactivity decisions. In particular, it
considered Williams Barber and the Divisional Court decision upholding the decision. The
Vice-Chair also considered HammondMaier, one of her decisions, in which the Board rejected
full retroactivity and the concept of employee awareness. The Union argued, as it did before me,
that the grievors should be paid retroactively to their first anniversary date and that there was no
17
reason not to follow the approach in Williams Barber. The Union also submitted that
Hammond Maier was decided on its particular facts and that it did not establish general
principles.
In concluding that it would not depart from the 20-day retroactivity rule, the decision
states as follows:
[The Board]. . . agrees with the Union's argument that HammondlMaier responded to a
particular set of circumstances and that the ruling in the award does not establish
principles of retroactivity. The Board rej ects the argument of the Employer that the fact
the Grievors were classified at the time they grieved, renders them ineligible to receive a
remedy which would affect their pay during the period when they were unclassified and
which continues to affect their compensation. The Board also rejects the Union's
argument that a balancing of the interests between Employee and Employer is
inappropriate in the case at hand and that retroactivity should, as in Williams/Barber, date
from the date of the beginning of the breach, that is the first anniversary date of each
Grievor. The twenty-day rule applied to retroactivity is one of the means by which
interests of both parties are balanced and is based on the time limit set out in the
Collective Agreement for the filing of grievances. It relates to the obligation of a Grievor
to bring a grievance to the attention of the Employer within this agreed-upon time frame
rather than withholding the information thereby placing the Employer at a disadvantage.
In the case at hand, the Employer was placed on notice on January 18, 1992, when Mr.
Bishop filed the grievance on behalf of the twelve Grievors. The Board has concluded
that it is appropriate for the Grievors to receive retroactivity in relation to that date. In
other words, they are to be moved to Level 2 of the Correctional Officer 1 Classification
20 days prior to January 18, 1992, and the Board so orders. The result of this is that they
will be in Level 2 at the time they moved into the Correctional Officer 2 Classification
and this is to be reflected in the adjustment to their pay. The Grievors are to receive
interest at 7% compounded annually.
The Board specifically declined to follow the approach in Williams Barber, even though
the grievances before it were filed in the same Ministry and the Employer was obviously aware
of the decision. The Board also noted that the 20-day rule is designed to balance the relevant
interests. The fact that the grievors were unaware of a violation when they grieved did not result
in a departure from the rule.
18
The other case is Re OPSEU (Union Grievance) and Ministry of Solicitor General and
Correctional Services, supra, a decision of Vice-Chair Kaplan dated November 27, 1995. The
subject matter of the grievances in that case was holiday pay under a compressed work week.
On August 11, 1992, the Board had issued a decision referred to as Simcoe et al dealing with the
entitlement of Residential Counsellors in the Ministry of Community and Social Services ("the
MCSS") to holiday pay under a compressed work week. The MCSS and OPSEU resolved the
outstanding holiday pay issues in a Memorandum of Settlement dated November 25,2994, in
which they selected a retroactivity date of September 28, 1992. Subsequent to the release of
Simcoe et ai, in excess of one thousand holiday pay/compressed work week grievances were
filed in the Ministry of Solicitor General and Correctional Services ("the MSGCS"). Fifty-two
grievances were filed in December of 1992, with the earliest filed on December 17, 1992. One
of the early grievances explicitly referred to the Simcoe et al decision. In December of 1994, the
MSGCS changed its practice in this area to comply with the Collective Agreement and its new
policy was applied retroactively to November 1, 1994. One of the issues in the case was whether
the grieving employees were entitled to compensation for the period prior to November 1, 1994.
The Union took the position that the retroactivity date should be 20 days prior to the issuing of
the Simcoe et al decision, since this was when the employer first became aware of the breach.
As alternatives, the Union argued that September 28, 1992, the retroactivity date selected in the
MCSS should be the governing date, or December 17, 1992, the date when the first grievance
was filed in the
MSGCS.
In determining the proper retroactivity date, the Board found it was appropriate to depart
from the 20-day rule. However, it did not select a date based on the release of the Simcoe et al
19
decision or one based on the one selected in the MSGCS. Instead, it selected the date of
December 17, 1992, and set out its reasons for doing so as follows:
. . . Without undertaking a detailed analysis of the differing positions of the parties, it
seems to me, on the facts of this particular case, that retroactivity should not begin until
this Ministry received a grievance alleging a breach and referencing the GSB's decision
in the Simcoe case. Once the first grievance was filed formally bringing to the Ministry's
attention an allegation of a violation of the Collective Agreement along with a decision of
the Board finding that the exact same practice in another Ministry was contrary to the
Collective Agreement - and it was an agreed fact between the parties that this Ministry
was notified of the Simcoe case in one of the earliest December grievances that was filed
- the employer acted at its own peril by not expeditiously addressing the issue.
This is not a case of the Ministry simply receiving notification of an alleged
breach of the Collective Agreement through the filing of one or more grievances. If it
were, the result of this award would be much different, and would have, almost certainly,
resulted in the application of the usual retroactivity rule. Rather, this is the case of the
Ministry receiving numerous grievances, many of which referenced a decision of this
Board stating that a practice that existed in another Ministry, in all material respects
identical to a practice in this Ministry, was contrary to the Collective Agreement.
Another panel of this Board made that finding, and decisions of this Board are final until
overruled. Not only was this decision not taken to judicial review, it was eventually
implemented in full. The ministry can hardly, in these circumstances, claim to be taken
by surprise. Nor can it state that it was awaiting a finding of this Board. This Board had
made a finding, and that finding was communicated to it.
The date of communication is, of course, important... Nevertheless, I also find the
issuance of a GSB award is not necessarily sufficient, at least it is not in this case (being
somewhat sensitive to the size and diverse operations of government), to bind every
Ministry insofar as a retroactivity date is concerned should other grievances alleging the
same violation of the Collective Agreement subsequently be filed referencing one of the
Board's awards. Obviously, there can be no hard and fast rule. What there must be is a
measure of common sense applied to the facts of particular cases. .. The important date
in the instant case, in my view, is the date when a grievance was first filed bringing both
the alleged violation of the Collective Agreement to the attention of the Ministry along
with the Simcoe award.
For our purposes, it is significant that the Board departed from the 20-day rule only in
circumstances where a grievance had been filed in the MSGCS along with a reference to a GSB
decision in another Ministry. The filing of a grievance in the MSGCS was critical for
determining a retroactivity date and a decision in another Ministry was not determinative. The
20
mere filing of a grievance without referencing the GSB decision would not have warranted a
departure from the rule.
In the case at hand, I find that there is no equitable justification that would warrant
departing from the 20-day retroactivity rule. There is certainly no justification for awarding full
retroactivity given that the circumstances here are not exceptional. Williams Barber is not
persuasive on the issue of retroactivity, whereas the approach in Re OPSEU (Elliott et al), supra,
is persuasive. The 20-day rule balances the relevant interests between employee and employer,
and an employee's awareness of a violation is not a valid consideration.
There is also no justification for selecting a retroactivity date of March 18, 1992. Since
the consensus is that Hammond Maier did not establish general retroactivity principles and its
particular result represents a practical compromise, there is no valid reason to select March 18,
1992 as the retroactivity date for these grievors. In any event, the circumstances involving merit
pay in the MCS has little relevance when selecting a retroactivity date for grievances filed in the
MAG. Although the MAG was aware of Williams Barber, the first claim regarding merit pay
made against the MAG was when Ms. Fazakas and Ms. Difederico filed their grievances in
August of 1992. It would penalize the Employer in these circumstances if retroactivity were
granted beyond 20 days prior to August 6, 1992.
I do not agree with the Employer's contention that no remedy is appropriate for Ms.
Difederico and Ms. Fazakas in light of the MAG Policy. The MAG decided to alter its practice
of not providing merit pay to unclassified employees in October of 1991. It is not particularly
surprising that it elected to wait for the judicial review of Williams Barber before it implemented
the MAG Policy. The MAG implemented its policy relatively soon after the Divisional Court
21
decision in Williams Barber, but not before the renewal of the unclassified contracts in April
1992. As noted previously, the prospective nature of the MAG Policy meant that employees
would not benefit from it until April 1993, when unclassified contracts were renewed again.
Contrary to the Union's suggestion, there is no concrete evidence to suggest that the Ministry
timed the implementation of the MAG Policy to improperly delay merit increases to unclassified
employees. However, there is no reason for the remedy in this case to be governed by the
prospective feature of the MAG Policy. The Board in HammondMaier indicated that the
commencement date of July 1, 1992, for the MCS Policy was not determinative since "it appears
to have been selected quite apart from the grievance and arbitral processes." In my view, these
comments apply equally to the MAG Policy. Ms. Difederico and Ms. Fazakas were entitled to
merit pay when they filed their grievances and it is only appropriate to apply the usual
retroactivity rule.
Accordingly, the grievances dated August 6, 1992 are allowed in part. The Employer is
directed to compensate the grievors for any losses attributable to its failure to pay merit pay to
the grievors for the period commencing 20 days prior to August 6, 1992, with interest calculated
in the usual way. I will remain seized of these grievances.
Dated at Toronto, this 20th day of April, 2006.