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HomeMy WebLinkAbout1991-0745.Khan.93-02-25~ ONTARIO EMPLOY~'S DE LA COURONNE ~ . 'CROWN EMPLOYEES DEL'ONTARIO GRIEVANCE C,OMMISSlON DE SETTLEMENT REGLEMENT BOARD DES GRIEFS IBO DUNDAS STREET WEST. SUJTE 21~, TORONTO. ONTARIO. M5G ~Z8 TELEPHONE/T~L£PHONE: [~76) 326-~388 t80, RUE DUNDAS OUEST, BUREAU 2~00, TORONTO (ONTARIO). MSG ~Z8 FAC$1MILE/T~L~COPlE .. (4~6) 326-r$96 745/91 IN THE MATTER OF AN ARBITRATION Un,er THE CROWN EMPLOYEES COLLECTIVE BARGAXNXNG ACT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN OPSEU (Khan) Grievor - The Crown in Right of Ontario (Ministry of Housing) .Employer BEPORE: S. Stewart Vice-Chairperson T. Browes-Bugden Member F. Collict Member FOR THE A. Ryder UNION Counsel Ryder, Whitaker, Wright & Chapman Barristers & Solicitors FOR THE C. Slater EMPLOYER Senior Counsel Management Board of Cabinet October 1, 1991 January 22, 1992 February 13, 1992 DECISION Mr. A. Khan alleges that he was unjustly dismissed from his unclassified position with the Ministry of Housing. On the second day of hearing Ms. T. Browes-Bugden replaced Mr. W. Rannachan as the Union member of the panel. The parties consented to this substitution. Following the hearings in this matter counsel submitted written argument to the Board. Mr. Khan commenced his employment at the Housing Supply Policy Branch of the Ministry in April 1986 in a Go Temp position. Mr. Khan obtained an unclassified appointment as a data entry clerk for the term March 2, 1987 to August 28, 1987. There were a number of renewals of this contract within this branch, the details of which will be addressed below. Mr. Khan did not receive a renewal of his contract following the expiry of a contract on March 31, 1991. The Union alleges that Mr. Khan was improperly dismissed and relies on Beresford, 1429/86, (Mitchnick) and the decisions that have followed it in support of his position. Alternatively, the Union claims that Mr. Khan,s applications for classified positions were not fairly considered. The Union's position in this regard was based on the existence of a dispute about the proper description and comparable classification of Mr. Khan's position for the period April 1, 1990 to October 19, 1990. Mr. Ryder's submission was that this dispute resulted in the grievor's applications not being fairly considered. With respect to this latter position we note that there was some suggestion in Mr. Ryder's opening remarks of bi~s against the grievor on the basis of age in connection with one particular application. The person to whom statements indicating bias against Mr. Khan were attributed denied making those statements and he was not cross-examined in this regard. This matter was not pursued by the Union in argument and accordingly we will not address this particular'aspect of the Union's claim that Mr. Khan's applications for other positions in the Ministry were not fairly considered. The remedy sought in connection with both claims is that the grievor be appointed to the classified service and that he be compensated for his losses in connection with ~he termination of his employment. As previously noted, Mr. Khan commenced his emplolrment as a Go-Temp in the Housing Supply Policy Branch performing the work of a data entry clerk. He obtained the first of five successive unclassified contract positions commencing March 7, 1987. Mr. Khan's position was equated with an OAG 4 classification. Mr. Khan came to assume duties in addition to those of a data entry clerk which resulted in a request on his part that his position be equated with a higher classification. This was the subject of some correspondence and discussion between Mr. Khan and members of management. It was initially decided by management that his duties were appropriately equated with an OAG 7 position however this was not satisfactory to Mr. Khan and the matter was pursued further. The ultimate result, as set out in a memorandum dated March 22, 1991 fromMr. C. Sparling, Director, Strategic Planning and Research Branch, was that for the period April 21, 1990 to October 19, 1990, Mr. Khan's position was equated with an OAG 9 level and he was compensated retroactively. Mr. Khan remained of the view that this was not an adequate level of compensation. However, the result was not changed. In 1990, the Ministry of Housing went through a process of restructuring which included the re-organization of its policy section. This re-organization resulted in the branch in which Mr. Khan had been employed, the Housing Supply Policy Branch, being disbanded. This process took place between June and October, 1990. One of the newly created branches was the Housing Policy Branch. Ms? C. Parrish was appointed Director of this Branch. Mr. Khan obtained a further contract for the term April 1, 1990 to March 31, 1991. He was assigned to the newly created Housing Policy Branch in the fall of 1990. Mr. Khan testified that he continued to carry out some of the duties that he had performed previously in addition to newly assigned duties which included co-ordination of committees and drafting correspondence. There was some dispute about the precise nature of those duties however it unnecessary to resolve that dispute in order to determine this grievance. Mr. Khan's position was initially equated with the OAG 4 classification however it was subsequently upgraded to OAG 6. Mr. But, Mr. Khan's new supervisor, testified that it was as a result of his efforts that Mr. Khan's position was upgraded. Ms. Parrish testified that she advised all contract employees, in61uding Mr. Khan, that their contracts would not be renewed on their termination. ~owever, there were a number of permanent positions available in the new structure which they could apply for. Mr. Khan's evidence was that he was aware that his contract "may not" be renewed, but that he was told by his immediate supervisor, Mr. N. But, to "keep his fingers crossed". He stated that he was not finally made aware that his contract would not be renewed until the last day of his employment. Mr. But testified that he specifically advised Mr. Khan that his contract would not be renewed. He stated that he pursued the possibility of a renewal but that he was unsuccessful. He further testified that he encouraged Mr. Khan to apply for other positions, and that he made a comment about "keeping fingers crossed" in connection with wishing Mr. Khan luck in obtaining another position. Ms. Parrish also testified that she encouraged Mr. Khan to apply for permanent positions that had been created as a result of the re-organization. She further advised him that he would be given an interview for any positions he applied for in her department. Mr. Khan applied for a number of positions both within and outside the Ministry of Housing however he was unsuccessful in obtaining a position. He was offered an interview only with respect to two positions for which he applied, both of which were in the H~using Policy Branch. He was unsuccessful with respect to one of those positions and he withdrew his application in connection with the other position prior to his interview. The reason that Mr. Khan withdrew his application with respect to this latter position was that he felt that he would not be awarded the position as another candidate was sure to obtain it and he would not beseriously considered for it because of his age. Ms. L. Gold, a member of the Ministry's human resources department, attempted to persuade Mr. Khan not to withdraw his application however she was not successful. We will deal first with the union's submission that Mr. Khan was denied procedural fairness in the handling of his applications for positions following the reorganization. In this regard, Mr. Ryder relied on this Board's decision in Grummett 1656/90, (Keller). In that case it was concluded that the grievor's request for an "overage appointment" had not been fairly considered in that she was not provided with the true reasons for the decision not to extend her employment and thus was deprived of an opportunity to address those reasons. Mr. Ryder submitted that the Employer has failed to meet an onus to explain why the grievor was not successful in obtaining interviews for the many positions that he applied for. He argued that the members of management "must have found the grievor's persistence tiresome" and argued that absent an explanation from the Employer witnesses with respect to the reason that he was not offered interviews we should conclude that he was "frozen out" in terms of being fairly considered for the positions. We are unable to conclude that any procedural unfairness in connection with the consideration of Mr. Khan's applications has been established. The evidence before us does not establish a Drima facie case such that the onus shifts to the Employer to provide an explanation. The evidence establishes that Mr. Khan unsuccessfully applied for a number of positions. We agree with Mr. 7 Slater's submission that without further evidence of the relationship of Mr. Khan's qualifications to the qualifications for those positions or evidence relating to any other aspect of the competitions, a prima facie case that Mr. Khan was treated unfairly has not been established. While there was a dispute about the level of Mr. Khan's position, that dispute took place primarily through Mr. Khan's former supervisor, Mr. Sparling, and related to his work prior to the re-organization. There did not appear to be any particular acrimony associated with this dispute. Indeed, the evidence established that subsequent to the termination of Mr. Khan's employment Mr. Sparling provided Mr. Khan with some advice about his resume and forwarded his resume to a management employee in the Ministry in an attempt to assist Mr. Khan in finding a position. Ms. Parrish also made efforts to assist Mr. Khan in finding a position, as did Mr. But. The evidence before us simply does not establish a prima facie case of procedural unfairness. Accordingly, we reject this aspect of the Union's claim. We turn now to the Union's position based on the Beresford line of cases. It was the submission of the Union that Mr. Khan was engaged to meet the ongoing staffing requirements of the Ministry both prior to and subsequent to the reorganization. It was argued that 8 ongoing staffing requirements of the Ministry must be filled by classified appointments. It was the position of the Employer that Mr. Khan was properly appointed to Group 4 of the unclassified service for the contracts that covered the period following the establishment of Group 4. In the alternative, Mr. Slater argued that Mr. Khan was properly appointed to Group 1 of the unclassified service. It was the Employer's position that the Board should confine its considerations to the circumstances that existed at the time Mr. Khan's final contract expired. The Employer's position was that the grievor was not entitled to challenge the non-renewal of his unclassified contract. The relevant statutory provisions are sections 6, 7, 8 and 9 of the Public Service Act and Regulation 881/89 made pursuant to that Act.' These provisions state as follows: 6. (1) When a vacancy exists in the classified service, the deputy minister of the ministry in which the vacancy exists shall nominate in writing from the list of eligibles of the Commission a person to fill the vacancy. (2) The Commission shall appoint the person nominated under subsection (1) to a position on the probationary staff of the classified service for not more than one year at a time. 7. The Commission shall, if requested in writing by the deputy minister, recommend to the Lieutenant Governor in Council the appointment of a person on the probationary staff of the classified service to the regular staff of the classified service, and the recommendation shall be accompanied by the certificate of 9 qualification and assignment of the Com~_ission. 8. (1) A Minister or any public servant who is designated in writing for the purpose by him may appoint for a period of not more than one year on the first appointment and for any period on any subsequent appointment a person to a position in the unclassified service in any Ministry over which'he presides. (2) Any appointment made by a designee under subsection (1) shall be deemed to have been made by his minister. ~ 9. A person who is appointed to a position in the public service for a specified period ceases to be a public servant at the expiration of that period. Regulation 881 6. (1) The unclassified service consists of employees who are employed under individual contracts in which the terms of employment are set out and is divided into, (a) Group 1, consisting of employees who are employed, (i) on a project of a non-recurring kind, (ii) in a professional or other special capacity, (iii) on a temporary work assignment arranged by the commission in accordance with its program for providing temporary help, (iv) for fewer than fourteen"hours per week or fewer than nine full days in four consecutive weeks or on an irregular on on-call basis, (v) during their regular school, college or university vacation period or under a co-operative educational training program; (b) Group 2, consisting of employees who are 10 employed on a project of a recurring kind, (i) for fewer than twelve consecutive months and for fewer than, (a) 36 1/4 hours per week where the position, if filled by a civil servant, would be classified as a position requiring 36 1/4 hours of work per week; (b) 40 hours per week where the position, if filled by a civil servant, would be classified as a position requiring 40 hours of work per week, (ii) for fewer than eight consecutive weeks per year where the contract of the employee provides that the employee is to work either 36 1/4 hours per week or 40 hours per week, (c) Group 3 consisting of employees appointed on a seasonal basis for a period of at least eight consecutive weeks but less than twelve consecutive months to an annually recurring position where the contract provides that the employee is to work either 36 1/4 hours per week or 40 hours per week; (d) Group 4 consisting of employees, (i) who are appointed pursuant to s. 8 of the Act, whether or not the duties performed by them are, or are similar to, duties perfo.rmed by civil servants, and (ii) who are not employees that belong to group l, 2 or 3. O. Reg, 24/86, s. 3(1), ap_~; O.Reg. 1 129/89, s. 1. We received detailed written submissions from counsel with respect to the Beresford decision of this Board and the decisions that have subsequently been issued by this Board dealing with the same issue. Prior to the decision in Beresford, the jurisprudence of the Board, as articulated in cases such as Ministry of Correctional Services & OPSEU (Simpson) (Kennedy) 694/85, was that the effect of s.9 of the Public Service Act and the provisions of the Collective Agreement was that unclassified employees were precluded from challenging their termination from employment upon the expiry of an unclassified contract and the decision not to renew it. In Beresford, supra, which was decided prior to the amendment to section 6 of Regulation 881 by the addition of Group 4, the Board found that an unclassified employee whose contract was not renewed had been improperly appointed to the unclassified service as the position did not involve duties that fell within any of the three groups referred to in section 6 of the Regulation as it existed at that time. The groups as defined were considered to be exhaustive and the Board held that an appointment which did not fall within one of those groups was not contemplated by section 8 of the Public Service Act and was therefore improper. There is reference in that decision, to the fact that the work performed by that grievor was not of a temporary or non-recurring position, The Beresford decision was upheld on judicial review and provided the basis for the Board's jurisprudence'with respect to this matter. Subsequent to the decision in Beresford Regulation 881 was amended by the addition of subparagraph 6(d), the provisions of which are reproduced above, creating Group 4. This amendment was effective March 13, 1989. In Parry, 237/91 (Low), the first decision of this Board following this amendment, the Union's argument that there is an underlying requirement that an appointment to the unclassified service must be in relation to a position that is temporary in nature in order for such an appointment to have been made in accordance with section 8 of the Public Service Act was rejected. At p. 5 of that decision the Board states that: The provisions of section 6 (1) (d) defining Group 4 of the unclassified service is [sic] unambiguous in that it appears to catch all employees who do not belong to Groups 1, 2 or 3, and includes employees whether or not their duties are similar to those performed by civil servants (i.e. classified employees) provided that the appointment was pursuant to section 8 of the Act which requires that the first appointment be for no more than one year. Aside from this restriction with respect to the first appointment, as well as the restriction contained in Article 3.15.1 of the Collective Agreement, reproduced above, the conclusion of the majority in the Parry case is that the Employer is not restricted in its ability to appoint to the unclassified service. The effect of the amendment to the regulation was 13 considered by another panel of this Board in Lavoie 441/91 (Keller). In that decision, the majority concluded that Parry was wrongly decided. At p. 13 the Board states as follows: ...we must conclude that in both Beresford and Bressette the Board was saying that an appointment to the unclassified service must be of the type that distinguishes it from the "normal" "permanent" positions in the classified service. In our view Group 4 appointments, even though wider in nature than those in Group 1, 2, or 3 nevertheless are equally restricted and the addition of the Group can not, of itself, expand the meaning of Section 6 of the Act. It can create a new category of appointments which must continue to be, as stated in Beresford "distinguished ... from the "normal" "permanent" position in the classified [service]". The Board in Bressette stated that the parties could not in the collective agreement expand the statutory powers of appointment. The same holds true for the employer. It can not expand the statutory powers of appointment indirectly through the Regulation. The latter must conform to the Act and not vice-versa. Thus it is our conclusion that Group 4 does nothing more than expand on the types of appointments that may be made to the unclassified service but can not be said to negate the previous decisions of the Board that have defined the scope of $. 8 of the Act. The end result, then, is that an inquiry must still be made to determine the nature of the appointment as that will determine whether it is properly a s. 8 appointment or not. The matter was further considered by this Board in Porter, 428/90, 1640/90 and 1641/90 (Brandt), Sin~h 331/91, (Dissanayake), Justus, 879/91 (Knopf) and Jafri, 933/91, 935/91 (Dissanayake). In Jafri, the conflict in the Board's jurisprudence following the amendment is fully addressed. In all of those decisions the Board dealt with 14 a situation of an individual who alleged that he or she was improperly appointed to the unclassified service by virtue of the ongoing work of the position. In all of those cases the Board took the same approach that was taken in Parry. The decisions contain somewhat different reasoning, however the essence of these decisions is that the amendment to s. 6(1) of Regulation 881 which created Group 4 clearly contemplates the appointment of persons to the unclassified service notwithstanding the fact that the work performed is of a permanent, ongoing nature and that the provisions of s. 8 of the Public Service Act do not restrict the application of the appointment power to the unclassified service to "work of an irregular, unusual or temporary nature" as it is referred to at p. 25 of the Jafri decision. The analysis contained in these decisions is somewhat different, however in the Jafri decision, commencing at p. 22, the Board states as follows: We agree with Re Lavoie and Re Bressette that the regulatory power cannot be used to expand the statutory power of appointment in section 8. However, the more fundamental question is whether group 4 in fact constitutes an expansion of the statutory power, in other words, is group 4 inconsistent with section 8 of the Act? Neither Bressette nor Lavoie points to any particular language in section 8 which gives rise to a conclusion that an appointment under that section is limited to duties that do not form part of the employer's regular and on-going needs. Instead, both cases rely on the now often-quoted statement in Re Beresford which is quoted in the passage from Re Bressette set out above. There, Vice-Chairperson Mitchnick observes that the wording of section 8 of the Act would tend to support Mr. Ryder's argument that" there must be some- thinq about the job in its i~i~ial conception which distinguishes it from the normal "permanent" position in the unclassified service." [emphasis in the original] In our respectful opinion the foregoing observation does not form part of the ratio decidendi in R~ Beresford. This view is supported by the language used by the Vice-Chairperson Mitchnick. He makes no definitive finding in this passage. He simply observes that the wording "tends to support" a certain interpretation. Then he moves on to deal with what he considers to be the "more important" issue, namely the question of whether the appointment fits within one of the groups in section 6 of the regulations. The Board goes on to refer to the conclusions in Beresford, at p. 16, where that panel states, inter alia: ... we must find on the evidence that we do have that the position to which the grievor was appointed was not one which falls within any of the various situations encompassed by the 3 Groups set out in the regulations, and as contemplated by section 8 of the Public Service Act. We find, therefore, that the purported appointment of the grievor to the "unclassified" as opposed to the "classified" service was improper. The Jafri decision goes on to state.at p. 25: Even if we consider that statement in question from ~eresford to be part of its ratio, we are not at all convinced that "the something" that distinguishes an unclassified appointment alluded to by the Board is a reference to the nature of the duties to be performed by the appointee. It is of note that what the Board envisaged was something different about the job "in its initial conception". [emphasis in the original] At best, the observation in Beresford is vague. Beresford, Bressette and Lavoie do not point to any statutory language which may suggest that section 8 appointments are limited to work of an irregular, unusual or temporary nature. As already noted, we are not able to find any such language. In the absence of any statutory language to support such a finding, we cannot agree that the words "something different about the job in its initial conception" is a finding by the Board that appointments under section 8 cannot be made for positions performing duties required to carry on the employer's normal operations. The use of the words "in its initial conception" suggests that the Board may have been merely alluding to the limitation in section 8 that the initial appointment to the unclassified service must be for no longer than one year. The decision goes on to review some of the decisions that followed Beresford. At pp. 29-30 the decision concludes as follows: We find that there is no restriction in section 8 of the Act that appointments to the unclassified service are limited to positions that perform duties that are not a regular or ongoing part of the employer's operation. To read such a limitation into section 8 would in our view be to give the provision a meaning that the language could not reasonably bear. It follows from that finding that we must also find that group 4 of the regulation is not inconsistent or in conflict with section 8 and must be given effect to. In Justus, the Board reached the same conclusion as in Jafri. At pp. 18-20 of the Justus decision the argument that the amendment of Regulation 881 is beyond the scope of section 8 of the Public Service Act and that there is a conflict between the Beresford decision and the decisions in parry and Porter was addressed as follows: Clearly, the regulations cannot repeal or amend the enabling legislation. The Porter decision reviewed these principles and concluded that the regulatory amendment did not amend Section 8 of the Act because nothing within the Act limits the duration of appointments or requires them to be limited in duration:. But Porter and Parry suggested that the Minister's powers had been expanded. The union's frustration with this conclusion is based on the fact that it seems in conflict with the conclusion in Beresford that indicated that the language in Section 8 was significant: ... there must be something about the job in its initial conception which distinguishes it from the normal "permanent" position in the classified service. (page 14) Yet that same panel in the Beresford decision continued its analysis by mentioning that a more persuasive interpreting factor was that Section 6 of the Regulations set out various fixed term type of appointments. It is further to be recalled that when the Divisional Court considered the Beresford/ Miller issue, it also saw [section 6 of the Regulation] as an interpretive guide, "elaborating upon and perhaps defining the unclassified service to which Section 8 refers." It is therefore clear that the Regulations can aid in the interpretation of, but not amend Section 8 of the Act. What then is the effect of the creation of the Group 4 category? This Board came to recognize that Groups ! - 3 all have a temporary nature to them by virtue of the time and. sequential references throughout the section. But Group 4 then allows that anyone not within the Groups could fall within Group 4. This effectively broadens the concept and eliminates the elements of similarity and/or the "temporary" characterization of the unclassified appointments. Thus we have to ask whether anything in Section 8 of the Act confines unclassified appointments to a concept of a "temporary" natUre as the Union wishes us to accept. It does at the outset by requiring that the first appointment may only be for one year, but it specifically allows that "subsequent" appointments may be for "any period". This allows the Ministry to appoint people to [the] unclassified service for "any period" whether it falls within the frames of Groups 1 18 to 3 or not. But Section 8 does also demand that the appointment be for a designated "period". It does not allow for open-ended, unlimited or permanent type of appointments to the unclassified staff. Otherwise there would be no purpose to the language "for any period on any subsequent appointment" [emphasis added]. The period of the appointment is a critical component to the appointment itself. The Justus decision then goes on to depart from the conclusion in Porter that section 8 does not impose a requirement that the appointment be for jobs that are limited in duration. The decision goes on to state: This panel finds, in Section 8, the requirement that the "subsequent" appointment be for a "period", but that the nature of that period is not limited as it previously was to the time restrictions set out in Groups 1 through 3. This interpretation preserves the distinction between the status of classified and unclassified staff that is apparent in the nature of the bargain between OPSEU and the government through their collective agreement and that was so ably pointed out by Mr. Ryder in his argument. It recognizes the permanent ongoing nature of appointments to the classified or civil service as distinct from the limited appointments and employment claims of the unclassified staff. This interpretation also seems logical in light of the newly negotiated Article 3.15.1 that allows, effective April 1, 1991 that if the same work is being done in the job for two years and there remains a continuing need for that work to be done on a full-time basis, the position will have to be recognized as within the classified service and duly posted and filled as a vacancy within the classified work force. This is a sensible balancing by the parties of the right of the Employer to make contractually limited, yet long term unclassified appointments, but checking it with the requirement to acknowledge a situation where a full- time permanent position exists if the need for the work continues beyond two years. We have quoted from the relevant decisions at some length, as the analysis contained in those decisions is thorough and detailed. We note that the issue raised in these cases is one that is presently the subject of a number of applications for judicial review, which will hopefully resolve the conflict in the Board's jurisprudence. In Ministry of Correctional Services & OPSEU (Union Grievance) 1140/91 the Vice-chair of this Panel reviewed these decisions and concluded that the analysis in Justus and Jafri was correct and that it was to be preferred to the approach taken in Lavoie. We note that the same approach was taken in Ministry of Transportation & OPSEU (Broom) 2293/90 (Gorsky). In his written submissions in this case Mr. Ryder has further developed some of the submissions that were made before other panels of this Board in connection with these decisions. However the essence of his submissions remain the same as those that have been considered and rejected by a number of panels of this Board. We are not persuaded that the provisions of the Public Service Act compel the conclusion that there is an obligation on the Employer to fill a position with a member of the classified staff when the work performed is the ongoing permanent work of the Employer. As well, we are not persuaded that this conclusion compels the conclusion that Bressette and Beresford were wrongly decided. Accordingly, even accepting that Mr. Khan was performing ongoing permanent work of the Ministry, we are unable to accept that the Employer has acted outside the provisions of the Public Service Act. Whether or not the relevant time is the time of the re-organization or the time of Mr. Khan's termination, the amendment providing for the addition to Group 4 was in effect. Mr. Ryder submitted that even if we were to accept that the Employer was able to make appointments to Group 4 to carry out permanent ongoing work, the failure to specifically designate Mr. Khan as a Group 4 employee subsequent to the effective date of the amendment of Regulation 881 by the addition of Group 4 precludes the Employer from characterizing his appointment as a Group 4 appointment. This matter was addressed in Parry and in Justus and the position put forward by Mr. Ryder in this regard was rejected. Again, we are not persuaded that these decisions were wrongly decided in this regard. For all these reasons it is our conclusion that no basis to challenge Mr. Khan's termination of employment upon the expiry of his final unclassified contract has been established and the grievance must be dismissed. Dated at Toronto, this25 day of February , 1993 $. L. Stewart - Vice-Chairperson "I Dissent" ~ ~ithout ~rittea reasons T. Browes-Bugden - Member F. ¢olli¢t - M~mbor