Loading...
HomeMy WebLinkAbout1991-1257.Lumley.93-02-23 1257/91 IN THE ~TTER OF ~ ~T~TION Under THE C~0~ E~P~YEES COLLECTI~ ~GAINING ~CT ~efore THE ~RIE~CE SETTLE~ . OPS~U (Lumley) Gr~evor - a~ The Crown in Right of Ontario (~inistry of Correctional 'Se~ices) ~loyer BEFO~: M. Gorsky Vice-Chai~erson J. Car~thers Me.er M. O'Toole Me.er FOR THE K. Whitaker ~ Counsel Ryder, Whitaker, Wright & Chapman Barristers & Solicitors FOR T~ S. Raymond ZMPLOYER Counsel ~icks, Morley, Hamilton, Stewart & Storie Barristers & Solicitors ~EARING August 24, 1992 2 BACKGROUND This grievance arises out of Mr. Lumley's having been denied an interview with respect to a management deve]opmental assignment at Metro East which 5e had applied for in the fa]] of 1990. In response to his application of October 29, 1990, J.A. Wallan, Regional Personnel Administrator, Metro Region, sent him a letter dated November 30, 1990 (Exhibit 3), which is as follows: Thank you for your interest shown in applying for the above noted program, The personal information contained in your application/ resume is collected under the authority of the Public Service Act, S.4(c), .So6(1) and S.24 and was used to assess your qualifications, All material relating to your submission was carefully analyzed by the program committee. You will hopefully have been verbally advised by now that you were, unfortunately, not selected to proceed to the next phase of the program. We realize that you will find this decision disappointing. We hope that you will not let it deter you in pursuing your career objectives. On behalf of the program committee, I would like to thank you once again for your interest in this program. We also wish you the best during the coming Holiday Season. In response to a request for particulars made by Julia Ravenscroft, Grievance Administration Officer, Grievance Administratioa & Negotiation, for the Employer, Mr, Whitaker, counsel for the Union, provided the particulars which ~re set out in Exhibit 8: I have now met with Mr. Lumley and can provide you with the particulars which you have requested. 1 DECISION THE GRIEVANCE The Grievor, Fernando Lumley, was at all material times a Correctional Officer 2, employed by the Ministry of Correctional Services at the Metropolitan Toronto East Detention Centre ("Metro East"), and he has a seniority date of January 4, 1982. On June 19, 1991, Mr. Lumley filed a grievance (Exhibit 1), as follows: "I grieve that management violated article A of the collective aqreement," and he requested by way of settlement: "1. Compensation for economic and non-economic losses. 2. Be provided with developmental assignments commensurate with my education and experience. 3. External investigation of complaints to Supt. Doherty June 5, 1991." Article A of the collective agreement, contains the heading: "NO DISCRIMINATION/EMPLOYMENT EQUITY," and is as follows: A.1 There shall be no discrimination practised by reason of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, se~, sexual orientation, age, marital status, family status, or handicap, as defined in section 9(i) of the Ontario Human Rights Code (OHRC). A.2 It is recognized that in accordance with section 13 of the OHRC, the Employer's employment equity program shall not be considered a contravention of this article. In the fall of 1990, Mr. Lumley applied for a management development assignment at Metro East, There were a number of other employees in addition to Mr. Lumley who applied for this position including Audrey Williams and Vince Daly. Ms. ~i]]iams, Mr. Da]y and M~. Lumley are black. None of the black applicants were granted interviews and three candidates who were awarded the developmental assignment, Rose Buhagiar, Dave McKinnon and Lee Anne Cannon are all white. Mr. Lumle¥ was troubled by the fact that he was not granted an interview despite his good performance record and education. After pursuing the issue of why he was not granted an interview nor considered for the position past the initial screening, he was informed by Stephen Small that the decision was based on a Memorandum which was sent to the Selection Committee by Mrs. D. Doherty, Superintendent. I have enclosed a copy of the Memorandum. The content of the Memorandum i~ inconsistent with Mr, Lumley's most recent PPRs and we say that in the circumstances, Mr. Lumley has been discriminated against on the basis of his race contrary to Article A.1 of the Collective Agreement. It is my intention to summons the material submitted by all candidates who applied for the developmental assignment, all documents relating to the selection procedure, interviews, and the personnel fi/es of all candidates, i would appreciate it if you could advise me whether or not the Ministry is prepared to provide this information without the necessity of a summons.. I would ask that you advise me by Friday November 15, 1991 as to whether or not the Ministry is prepared to produce this material. If I have not heard from you by that date I will be issuing a summons to the Deputy Minister for the documentation. Please let me know if there is any other information I can provide you ~ith about the nature of the Union's case. The memorandum referred to in Mr. Whitaker's letter, is dated November 19, 1990, and is as follows.: Although Mr. Lumley has applied for a developmental assignment, I have not seen any indication from Mr. Lumley's behaviour at Metro Toronto East Detention Centre that he has sufficiently achieved mn~g~ment capahiJities or even potential for leadership. Mr. Lum]ey has been enrol ]ed in the Business Administration Program at York University. Once he completes this course he would be well advised to pursue business administration opportunities through the competitive process. By letter dated November 15, 1991, Ms. Ravenscr0ft acknowledged receipt of Exhibit 8, and, in responding to Mr. Whitaker's request for documents, statedd 'In response to your request for documents, the ministry is prepared to disclose the following documents prior to the hearing date: · The documents pertaining to the prescreening process · The scoresheets used in prescreening the applicants · The material submitted by those candidates who were selected for an interview At the commencement of the hearing, counsel for the Union requested an adjournment. The reason for the request was based on a determination that had been made by the Union in July of 1992 that it would not be proceeding with new cases in the months of August, October and December of 1992 where it had retained outside counsel. We were advised that this determination was made as part of the fiscal restraint policy of the Union by the Union's grievance department, and that, in the noted months, new cases would only be proceeded with before the Grievance Settlement Board where the interests of the Union were being represented by grievance officers employed in the Union's Grievance Department. 5 After hearing argument from both parties on this issue, the Board ruled only that it would not be appropriate to grant an adjournment in the circumstances. Counsel for the Employer then proceeded to raise two objections to arbitrability, notice of which had been furnished to the Union prior to the previous date scheduled for the hearing on May 23, 1992. These objections were as follows: 1. That the grievance was Out of time and hence inarbitrable under the provisions of the Crowa EmplQyees Collective Bargaining Act. That the grievance was not arbitrable by virtue of the provisions of s.18(l)(b) of the A~/L, which is as follows: 18. - (1) Every collective agreement shall be dee~ed to provide that it is the exclusive function of the employer to manage, which function, without limiting the generality of the foregoing, includes the right to determine, (b} merit system, training and development, appraisal and superannuation, the governing principles of which are subject to review by the employer with the bargaining agent, and such matters will not be the subject of collective b'argaining nor come within the jurisdiction of a board. EVIDENCE The only viva voc9 evidence given at this preliminary stage was that of the Grievor, who testified: 6 1. After receiving Exhibit 3 from Mr. Wa]len, early in December of 1990, he attended on the Area Regional Personnel Administrator, Jim Morris, to express his disappointment at not being selected to proceed to the .next phase of the selection process, and to endeavour to obtain more information as to why.he had been "bypassed." Mr. Morris indicated that this information would better be obtained from Mr. Wallen, who was the chairperson of the selection committee. Mr. Morris did refer to the large number of applications received and noted that a significant number of applicants had not been invited to be interviewed. 2. He (the Grievor) tried to reach Mr. Wallen by telephone over the next few days and was able to reach him on the third try, Mr. Wallen indicated that he would send' a letter to the Grievor in response to his inquiries, but did not furnish any other information over the phone. 3. Mr. Wallen directed the G~ievor to Steve Small, who was said to have evaluated the Grievor's application and upon whose recommendation the Grievor was not selected to proceed to the next phase of the selection process. 4. After the above noted telepho'ne conversation with Mr. Wa~len, the Grievor tried, unsuccessfully, to reach Mr. Small by telephone. ? He thereupon attended personally on Mr. Small who said that he was too busy to see him at that time but requested that the Grievor arrange to see him accompanisd by a Union ~epresentative. 5. The Grievor emphasized that any delay in meeting with Mr. Small was as a result of the latter'~ indicatin9 his lack 6f immediate availability. In emphasizing that it was irrelevant to him whether he was accompanied by a Union representative, the Grievor indicated that his agreement.to meeting with Mr. Small along with a Union representative was solely based on Mr. Small's insistance that this be done. The Grievor also indicated that he made at least three attempts between December of 1990 and January of 1991 to arrange a meeting with Mr. Small, but to no avail. 6. As a result of his lack of success in obtaining a satisfactory explanation from the Employer for not qranting him an interview, the Grievor made a decision to obtain assistance from Alvin Curling, the t~n MPP for Scarborough North. We did not have before us the correspondence that passed between the Grievor and Mr. Curling nor Mr. Curling's letter to Mr. Wallen, however, the Union filed, as Exhibit 5, a letter of March 6, 1991 to Mr. Curling from Mr. Wallen, which is as follows: Thank you for your February 14, 1991 letter on behalf of Mr. Lumley, one of your constituents, regarding his application for the Metro Region Management Development ~rogram. on November 30, 1990 I wrote to Mr. Lumley advising him that he would not be granted an interview for the developmental program. I am quite prepared to provide Mr. Lumley with a detailed explanation as to why he was not selected. All he needs to do is contact the undersigned. I have taken the liberty of forwarding a copy of this letter to Mr. Lumley in order that he be aware of the process to follow. Thank you for bringing this matter to my attention. 7. Mr. Lumley, pursuant to Exhibit 5, attempted to arrange a meeting with Mr. Wallen, sometime in March of 1991, but Mr. Wallen, 'once again, directed him to Mr. Small, 8. Mr. Lumley again endeavoured to arrange a meeting with Mr. Small but was told by the latter that he had a "tight schedule" and would try to meet with him late in May of 1991, 9. The G~ievor tried to meet with Mr. Small on three or four occasions and on the one occasion that was available to Mr. Small, the Grievo~ was unable to obtain Union representation as he had been requested to do by 10. The G~ievor met with Mr. Small late in May of 1991 (he could not remember the exact date) when he said that M~. small gave him two documents supposedly relating to why he had not been granted an interview. 9 11. The meeting with Mr. Small was said to have taken place in Mr. Small's office at the Metropolitan Toronto East Detention Centre and lasted less than ten minutes. 12. At the meeting Mr. Lumley informed Mr. Small that he had been informed by Mr. Wallen that his being rejected from the program was as a result of submissions received by the selection committee, Metro Region Management, Development Program, from Mr. Small. 13. Upon receiving this advice, Mr. Small went to a cabinet in his office and pulled out the two documents, aSove referred to. One of these was the Grievor's current evaluation, the other being the letter from Ms. Doherty to the Selection Committee, dated November 19, 1990, set-out, above, at pp. 3-4. 14. As he handed the letter written by Ms. Dohert¥ to the Grievor, Mr. Small said: "You're not going to like this." The Grievor stated that he said nothing in return except "Thanks" and left Mr. Small's office. 15. The Grievor stated that as he was then too upset to speak further to Mr. Small, he prepared a memorandum {Exhibit 4), dated June 5, 1991, addressed to Ms. Doherty and Mr. Small, ·which he said he regarded as a "verbal grievance." Exhibit 4 is as follows: Subject COMPLAINTS AGAINST THE MINISTRY OF CORRECTIONAL SERVICES 10 1. I am charging that there was discrimination - very probably racially motivated, in the recruitment and selection of candidates for the Mana§ement Development Program. 2. I am charging that you abused the power vested in your office and carried out acts of irregularities while recruiting and submitting names of candidates for the Management Development Program. 3. I am charging that you violated the Ministry and the Public Service guidelines and submitted prejudicial statements about me to the selection committee, Metro Region, Management Development Program. 4. I am charging that you showed no interest in my application; you did not provide me with even the courtesy of an interview to find out what contributions I could have made to the Ministry. (Incidentally at the time of the competition I was studying Personnel Management at York University 'and was learning how I should have been treated). 5. I am charging that you the Superintendent and the Senior Assistant Superintendent (Corrections) have set your own agenda, to derail some of the changes the present and immediate past governments have been trying to implement. 6. I am charging that you have created unofficial file(s) on me without my knowledge or consent contrary to the guidelines of'the Public Service. 7. I am charging that there have been too many instances of differential treatment since you and the Senior Assistant Superintendent (Corrections) assumed your posts here at the Toronto .East Detention Centre. 16. A brief meeting was held between the Grievor and Ms. Doherty a few days after he delivered Exhibit 4 to her, the exact date not being given, nor 'were we informed as to who arranged for the meeting. However, at the meeting Ms. Doherty asked the Grievor if he felt discriminated against. According to the Grievor, Ms. Doherty did not wait for his reply but said to him: "I am a woman and I am peeved that you would suggest that you did not get the development position because of discrimination." According to the Grievor, Ms. Doherty was angry whefn she spoke to him and after making the quoted statement, asked him to leave her office. He stated that, in the circumstances, he did not have an opportunity to respond to Ms. Doherty. 17. According to the Grievor he first came to the conclusion that there had been a violation of article A.1 based on "discrimination practiced by reason of race, ancestry ... colour, ethnic origin ... as defined in section 9{1) of the Ontar%o Hu~a~ Rights CQ~ (OHRCk" between the date, in ]ate May of 1991, when he was given the two documents referred to at his meeting with Mr. Small, and June 19, 1991 when he filed his grievance. He regarded the documents as representing very unfair negative commentary with respect to himself. His conclusions were reinforced a~ a result of conversations he had with two other black candidates for the development program position who were similarly upset 'because of their perceptions that they had been discriminated against. He be]ievad that his conversations with the other black candidates had taken plac~ between May 31, 1991 and June 5, 1991, the latter date being the date of Exhibit 4. 18. Mr. Lumley stated that he first became aware of the existence of article Aol of the collective agreement between May 31 and June 12 5, 1991 when it was brought to his attention by the President of his Local. 19. In cross-examination, Mr. Lumley indicated that, based on the statements contained in paragraph 1 of Exhibit 4, he was of the opinion that he had been discriminated against by June 5, 1991 and not, as he had earlier, testified, between June 5 and June 19, 1991. This is because Exhibit 4 is dated June 5, 1991. 20. Further in cross-examination, Mr. Lumley stated that he believed that he had spoken to Mr. Curling in January of 1991 and had told him, at that time, that he suspected that he had been discriminated against by virtue of his non-selection for an interview for the development program position. He also acknowledged that he told Mr. Curling that he was aware, based on his discussions with Derek Miller, the Union President, that he could grieve his failure to be appointed to the development program position. 21. Further in cross-examination, Mr. Lumley testified that prior to his speaking to Mr. Small or Mr. Wallen he had spoken to a Union steward, Mr. McKinnon, and to Mr. Miller concerning his perceptions that he was being discriminated against because of his race, ancestry, colour, or ethnic origin, which converstaion took place shortly after he spoke to Mr. Curling. The Grievor stated that he had spoken to representatives of the Union on two occasions in 13 January and February 1991, at which times he informed them that he suspected that he had been denied an interview for prohibited discriminatory reasons. He believed that the Union president at that time told him about the applicability of article A.1. He later stated that he might have received this information in June of 1991, but acknowledged that in January of 1991 he had told Mr. Curling that he suspected he was being discriminated against, but that, at that time, he had no tangible proof in support of his suspicions. It is likely that his meetings with the Union representatives took place in January and February of 1991, as he testified in cross-examination that the meeting with Mr. Curling in January of 1991 took place around the same time as his meetings with the Union representatives. A~GUMENT FOR THE EMPLOYER ON THE PRELIMINARY OBJECTION BASED ON LACK OF TIMELINESS 1. Counsel for the Employer relied on the fact that the Grievor had notice of his not being selected for an interview shortly after November 30, 1990, when he received Exhibit 3, and only filed his grievance on June 19, 1991. This represented a six and a half month time lag. 2. Counsel for the Employer relied on the provisions of articles 27.1, 27.2.1, 27.2.2 and 27.3.1 and 27.13, which are as follows: 27.1 it is the intent of this Agreement to adjust as quick]y as possible any complaints or 14 differences between the parties arising from the interpretation, application, administration or alleged contravention of this Agreement, including any question as to whether a matter is arbitrable. 27.2.1 An employee who believes he has a complaint or a difference shall first discuss the complaint or difference with his supervisor within twenty (20) days of first becoming aware of the complaint or difference. 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 manner: 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. 27.13 Where a grievance is not processed within the time allowed or has not been processed by the employee or the Union within the time prescribed it shall be deemed to have been withdrawn. 3. Counsel for the Employer relied upon Gembora, 930/89 (Dissanayake), where the Board stated at pp.2~3: It is now well established by Awards of the Grievance Settlement Board that the time limits specified in Article 27 of t~e Parties' Collective Agreement are mandatory in nature and not directory. See Keeling and Ministry of Transportation and Communications, 45/78 (Prichard); and Parr and Ministry of Education, 317/82 (Swan). Article 27.2.1 of the Agreement reads: "An employee who believes he has a ~omplaint or a difference shall first discuss the complaint or difference with his supervisor within twenty 15 (20) days of first becoming aware of the complaint or difference." Article 27.2.2 reads: "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 manner:..." Article 27.9 provides that if the Grievance is not pursued within the time allocation provided in the Article, then it shall be deemed to have been withdrawn. ARGUMENT OF THE UNION WITH RESPECT TO THE TIMELINESS OBJECTION Counsel for the Union argued that: 1. The twenty day period provided for in article 27,2.1 of the collective agreement within which the Grievor must discuss his complaint or difference with his supervisor does not start to run until the Grievor has formed a belief that he has a complaint or difference. It was submitted that the Grievor did not have a basis for concluding that he was being discriminated against contrary to article A.1 until he received the documents from Mr. Small late in May of 1991. 2. Reference was made to the candour of the Grievor during cross- examination when he acknowledged the possibility of his being aware, in January of 1991, about the time he spoke to Mr. Curling, that his failure to obtain an interview was based on racial 16 discrimination by the representatives of the Employer. However, we were urged to find that it was not until the Grievor had access to the two documents furnished by Mr. Small in May of 1991, and had the benefit of considering his conversation with the two black co- workers referred to, that he had a sufficient basis for arriving at the conclusion that his rights under article A.1 had been violated when he was denied an interview. 3. We were asked to find that the belief required in article 27.2.1 was an actual belief, as the words did not read: "An employee who~ought to believe," and that the language employed in the article ought to be given its plain meaning. We were asked to find that the plain meaning requires a subjective test rather than an objective test with respect to an employee's belief. 4. Reference was made to Voron.ica Pierre, 492/86 (Verity) where the Board stated at pp.14-15: The language of the Collective Agreement appears to provide two quite separate and distinct procedures for the filing of individual grievances on the one hand, and the filing of union grievances on the other. In individual grievances, Article 27.2.1 states that the employee "who believes he has a complaint or a difference" shall raise it with his supervisor "within 20 days of first becoming aware of the complaint o~ difference" (emphasis added). 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. Vice- Chairman Samuels makes the point in OPSEU (p. Mitchell 17 and Union Grievance) and the Ministry of Government Services, 1614/85 and 1615/85 at p. 6: "Article 27.2.1 establishes a time limit which does not begin to run until the employee first becomes aware of the complaint or difference. And the words 'complaint or difference' refer to 'complaints or differences between the parties arising from the interpretation, application, administration or alleged contravention of this agreement'. (Article 27.1). In other words, the time does not begin to run until the employee is aware that there is a complaint or difference the collective agreement. Her complaint or difference in this sense is not being declared surplus, or being laid off, but her feeling that she has not been treated according to the collective agreement." On the other hand, in the filing of union grievances under either Article 27.8.1 or 27.8.2, there is no subjective component. As Arbitrator Brandt observed in OP~EU ~Union Grievance) and Management Board of Cabinet, 1546/85 at p. 5 in referring to the filin9 of union grievances: "Knowledge or awareness of the violation is not the appropriate basis on which to assess the beginning of the time period," 5. Reference was made to Ca~eron,' 2174/87 (Draper), where the Board stated at p.l: In our interim decision of July 20, 1988, we ruled that the disposition of this case must await the decision of the Divisional Court on the application for Judicial Review of the Board's decision Pierre, 492/86, a case which also called for an interpretation of Article 27.2.1 of the collective agreement. The Court's decision, which upholds the Board's decision, has now been reported: Ontario (M~rtistry of Correctional Services) v. O.P.S.E,U. [(1990),] 74 O.R. (2d) 700. 6. Further, at pp.2-3, the Board stated: The decisions of the Board and the Court in pierre confirm that the crucial time, for the purposes of Article 27.2.1, is that at which the employee first 18 becomes aware that a complaint or difference exists under the collective agreement and of the right to take steps to resolve it in accordance with the grievance procedure. The time within which the employee must act begins to run from the time when, in fact, he becomes aware of the complaint or difference. 7. It was also submitted that the twenty working days referred to in article 27.2.1 where, by virtue of article 27.14, "exclusive of Saturdays, Sundays and designated holidays." The time was said to run from May 31, 1991 when the Grievor is supposed to have attended upon Mr. Small and received the two documents referred to. In fact, the Grievor was unable to give the exact date of the meeting, but based on his recollection of when he sent Exhibit 4 to Ms. Doherty, we are prepared to find that the meeting took place on May 31, 1991, and if the position of the Union as to when time starts to run is accepted, the 9rievance would have been filed in time. 8. It was also argued that even if the grievance was not filed in time and. was deemed to be withdrawn pursuant to article 27.13 of the collective agreement as not having been "processed within the time allowed or has not been processed by the employee or the union within the time prescribed~" such failure had been waived. 9. Reference was made to Exhibit 6, being a letter dated Ju~y 19, 1991, addressed to the Grievor, from D. Cooley, Acting Regional Manager, Metro Region for the Employer, being the stage 2 reply in accordance with article 27.3.3 of the collective agreement, which is as follows: 19 In accordance with Article 27.3.3 of the Collective Agreement, a meeting was held with you and your representative on Tuesday, July 16, 1991 to hear your grievance which states: "I grieve that Management violated Article A of the Collective Agreement." The settlement desired states: "(1) Compensation for economic and non economic losses. (2) Be provided with developmental assignments commensurate with my education and experience. (3) External investigation of complaints to Supt. Doherty June 5, 1991." At the hearing your representative raised a preliminary objection to the designation of myself to hear this grievance, and for Mr. J. Morris to assist. At that point, I undertook to discuss the concerns raised with the Regional Director within seven days. I have now discussed the matter with the Regional Director. He indicates that both myself and Mr. Morris are appropriate designations to hear.this .grievance at Stage 2 and did not consent to change this designation. Therefore, since both you and your representative refused to present any evidence at our meeting of July 16, 1991 I have no option but to deny your grievance at this stage. 10. It was submitted that the grievance was denied at this stage, and there was no reference to an objection to the processing of the grievance based on a !ack of timeliness. 11. Reference was also made to a letter dated October 17, 1991, from Ms. Ravenscroft to Lester Yearwood, a grievance officer with the Union, requesting certain particulars, where no mention was made of the Employer's objection based on timeliness. This letter 20 was not filed with us but no objection was taken to its alleged contents. 12. Reference was also made to another letter written by Ms. Ravenscroft to Mr. Whitaker, which letter is dated October 31, 1991, which was written after she had received no reply from Mr. Yearwood. In that letter, no reference was made to any objection based on a failure on the part of the Grievor to comply with the time limits in article 27. Although the letter of October 31, 1991 was not filed with us, there was no objection takem to its being referred to or to the accuracy of its alleged contents. 13. Mr. Whitaker wrote to Ms. Ravenscroft on November 2, 1991 responding to her request for particulars. 14. On November 15, 1991 Ms. Ravenseroft again wrote to Mr. Whitaker, which letter, in part, indicates which documents she was prepared to disclose, however, there was no reference to any objection based on a lack of timeliness. 15. Reference was also made to a letter dated May 20, 1992, from Mr. Raymond to Mr. Whitaker, being part of Exhibit 7, where an objection to arbitrability is raised: Please be advised that I intend to 'make a preliminary objection at the commencement of the proceedings that the Grievance Settlement Board is without jurisdiction to hear this matter. The basis for my objection is that the selection for the Management Development Program is outside the ambit of the 21 collective agreement and therefore the Board has no jurisdiction to hear a grievance arising out of the selection of candidates to participate in that program. 16. Reference was also made to a further letter from Mr. Raymond to Mr. Whitaker, dated May 25, 1992, also being part of Exhibit 7, where Mr. Raymond indicated: As a further matter, please be advised that I intend to make a further preliminary objection at the commencement of proceedings that this matter is inarbitrable as the time limit specified in the collective agreement between the parties have not been adhered to. 17. It is on the basis of the steps taken by the Employer to deal with the grievance, without raising its objection based on timeliness, that such an objection was said to have been waived. 18. Counsel for the Union relied upon ~barakan, 1978/86 (Kirkwood), where a preliminary objection was raised by the employer disputing the Board's jurisdiction based on. the union having referred the grievance to the Board for hearing beyond the mandatory time limit set out in article 27.4 of the collective agreement. At pp.3-5, the Board stated: The Board finds that the application which was made by the union on March 2, 1987 for a hearing, was grossly beyond the time limits set out in article 27.4 and the employer was entitled to successfully make its objection that the Board would have no jurisdiction because of Article 27.3, 27.13 and 27.16 unless it could be found that the Ministry waived the time limits by its actions and omissions. Other cases which have come to the Grievance Settlement Board have applied these articles of the collective agreement in the same manner. The cases of ~ and McI~aac, Grievance Settlement Board, #742/83 and 24/84 and the ~ case, Grievance Settlement Board #377/8 clearly support the proposition 22 that the time limits set out in Article 27.3 are mandatory, and by virtue of Article 27.13 the grievance would thereby be considered to be withdrawn if it has not been processed within those mandatory time limits. The Board does not have the jurisdiction under Article 27.16 to enlarge the time limits. However, contracting parties themselves may waive the mandatory time limits in the collective agreement (~nderson, Grievance Settlement Board, #1483/84 (G. Brent;). This can be done either by express agreement or as Gall Brent states in that award, at page 5: "By the action of the "innocent" party in failing to object to the procedural irregularity in a timely fashion. We believe that at page 210 of Collective Agreement Arbitration in Canada Professor Palmer correctly summarised the situation when he wrote the following: 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 includes: allowing a grievance to go through the grievance procedure; failure to object at the first opportunity to the grievance procedure;.., and an attempt to settle the grievance. Waiver can also be 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 is not raised again until the hearing. Generally, waiver arises therefore where it is clearly indicated that one of the parties does not intend to invoke the procedural provisions of the collective agreement. There is no need for detrimental reliance by the other party... The onus of establishing waiver is on the party alleging it". Thereby, the issue is whether or not the "innocent party", the employer,' acted in such a manner to lead the union to believe that the objection was waived. In the McNamara c~se, Grievance Settlement Board, #272/81, grievances were filed several months after the time limit and it was clear that the union had failed to comply with the fifteen day requirement in the collective 23 agreement. The employer did not notify the Registrar that it was taking the position that the grievances were inarbitrable because of the failure to comply with the time limits and discussed the grievance as an "alive" grievance in the context of the mediation. The union counsel did not become aware until the day before hearing that this objection was going to be made. The Board held, after considering ~e _U.S.W. and CQ~structio~ Products, Canadian Division, (1970) 22 L.A.C. (2d) 125 Brown, that where the defect was apparent on its face and the employer failed to raise the objection until the hearing, the defect is waived. 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 grievance 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 next step in the 9rievance and lead the union to believe that there was no objection to the arbitrability of this grievance. If the employer had intended to resolve t.he merits of this case, without waiving its right to raise its objection, the objection should have been raised prior to the mediation 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 the grievance was bein§ processed and by participating in the mediation again without making an objection, the Board finds that the employer waived the objection to the time limits which would otherwise have been available to successfully argue that the Board had no jurisdiction, The board finds that the union was able to establish that the employer did waive the time limits by its actions and omissions and that the employer failed to show that its objection to the jurisdiction was made in a timely fashion. 19. It was the position taken on behalf of the Union that the Employer was aware of the alleged breach with respect to the time 24 limits not having been met and, notwithstanding that awareness, it continued to take steps in the grievance procedure. It was only on May 25, 1992, after the postponement of the hearing date scheduled for May 23, 1992, that counsel for the Employer first raised an objection with respect to timeliness. 20. Counsel for the Union also relied upon Fun~/Anand, 1798/89, ' 104/90 (Stewart). In that case, one of the preliminary issues raised by the employer related to the timeliness of one of the grievances. There, the Board stated at pp.10-12: Mr. McKeown also emphasized that factual matters and legal arguments, such as timeliness objections, are fleshed out throughout the grievance procedure. While we agree in general with this proposition, the timeliness of Mr. Anand's grievance was clear from the information available to the Employer at the 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 is .applicable. The principle that these cases establish is that an objection based on non-compliance 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 25 waiver. Once a timeliness objection has been waived it cannot be revived by notice. RESPONSE OF THE EMPLOYER TO THE ARGUMENT THAT TIME ONLY BEGAN TO RUN ON MAY 31, 1991 1. It was submitted that even if the subjective test relied upon by the Union is the applicable one, the Grievor had acknowledged in cross-examination that he had informed Mr. Curling in January of 1991 that he regarded the Employer's action as having been made discriminatorily because of his race, and that he had indicated that this was the case to Union repreesntatives close to the time that he spoke to Mr. Curling, and that he acknowledged that he had then been informed about his right to grieve. Accordingly, time was said to have started to run in January of 1991. RESPONSE OF T~E EMPLOYER TO T~E WAIVER ARGUMENT RAISED BY THE UNION i. It was submitted that the Employer, in the case before us, did not have knowledge that the grievance had'not been processed in accordance with the 'time limits prescribed by the collective agreement. Reference was made to the Fung/Anand case at p.8. In that case the Board found that the Employer had know]edge that the grievance had not been processed in accordance with the time limits prescribed by the collective agreement, as it had adverted to the time limits in responding to the grievance. Because of the 26 fact that the employer proceeded to consider the grievance on its merits, the Board Concluded that it had waived its objection to timeliness. In reaching this conclusion the Board noted at p. 8 of its decision that: "... even though the onus is on the Union to establish the waiver, the onus is on the Employer to show that it made its objection in a timely fashion".. 2. It was the position of the Employer that the question of when it "had knowledge that the grievance had not been processed in accordance with the time limits provided by the collective agreement" ought to be decided using a subjective test, and it was submitted that it was not until the date of the commencement of this hearing that it finally had the evidence that would enable it to conclude that the grievance was not timely. 3. It was submitted that on the facts of this case, although the matter was not the subject of objection, the grievance was filed without the Grievor having followed article 27.2.1. Prior to the filing of this grievance, the Grievor had not pursued a complaint, as the facts indicated that after he had received Exhibit 3 his attendance on Mr. Morris, who was not his supervisor, was not to discuss a "complaint or difference" but to find out why he had not been interviewed for the developmental position. His pursuing Mr. Wallen was, similarly, not to discuss a complaint or difference, but to find out why he had not been granted an interview, as Mr. Morris was apparently not in a position to furnish him with the 27 information he sought. When he was directed to Mr. Small by Mr. Wallen, he pursued the matter further. The evidence indicates that the purpose of meeting with Mr. Small was to obtain the information that he first tried to get from Mr. Morris and Mr. Wallen: the reason why he had not been granted an interview for the developmental position. 4. Apparently, the first indication that the Grievor had a complaint or difference, as set out in article 27,1 of the collective agreement, was when he met with Ms. Doherty a few days after June 5, 1991, when the Grievor regarded himself as having presented a "verbal grievance." 5. Counsel for the Employer submitted that if the Union is correct and a subjective test is to be employed as to when an employee believes he has a complaint or difference, then, given the form of the grievance, and, based on the evidence available to the Employer, it can reasonably be seen that it did not have knowledge that the time limits prescribed in the collective agreement were not adhered to until the comm%encement of the hearing. 6. Although the Employer would be aware that the Grievor had been informed on November 30, 1990, through Exhibit 3, that he had not been selected to proceed to the next phase of the program, there was no obvious link between that communication aad the grievance filed on July 19, 1991, so as to lead to the reasonable conclusion 28 that the Employer was fixed with knowledge that the grievance had not been processed in accordance with the time limits prescribed by the collective agreement prior to the commencement of the hearing. Counsel for the Employer argued that, unlike the case in Fung/Anand, where the Board found, at p.8, that the employer "had knowledge that the grievance had not been processed in accordance with the ti'me limits prescribed by the collective agreement as it adverted to the time limits in responding to the grievance," on the facts before us no such conclusion could be reasonably arrived at. 7, Counsel for the Employer argued that the Employer should not be prejudiced by the fact that it only raised an objection to arbitrability based on a failure to adhere to the mandatory time limits in its letter of May 25, 1992; such notice, in the circumstances, represented a precaution taken without it being clear that the time limits had not been adhered to. There may have been a suspicion that this was the case, and the notice was intended to prepare the Union for an argument along these lines should the need arise. It was suggested that there was a difference between knowledge of facts indicating that the time limits had not been adhered to and certain circumstances that indicated that such facts might, indeed, exist. DISCUSSION OF THE TIMELINESS OBJECTION 29 1. The Divisional Court in the Cameron case {The Quee~ in Right of Ongario as Represented by the Ministry of Cor~ectiona~ Services v. O~tario Public Ser¥ic~ Employees Union ~nd the Grievanq¢ Settlement Board (1990), 74 0.R. (2d) 700, per O'Leary J., at pp.704-5, referred to the fact that the Court had, immediately after the hearing of the application for judicial review, disposed of it by an endorsement which stated: July 11, 1990 We are all of the view that the Board was correct in its conclusion that the 20-day time period within which the grievor had to bring her grievance, began to run only when she became aware that she had a complaint that was based on a violation or possible violation of the collective agreement. In our view, the "complaint or difference" referred to in Article 27.2.1 of the collective agreement is the same kfnd of complaint(s) or difference(s) mentioned in Article 27.1, that is to say a complaint or difference "between the parties arising from the interpretation, application, administration or alleged contravention of this agreement, including any question as to whether a matter is arbitrable." The grievor knew at least by November, 1985 that she was unhappy about a possible exposure to T.B., but she was not aware until late February, 1986 that such exposure might constitute a complaint or difference with her employer arising out of a contravention by it of the collective agreement. Until'she became so aware she could not have believed she had such a complaint. It is implicit in the reasons of the Board that the grievor first became aware that she had a complaint based on a violation or possible violation of the collective agreement on February 25, 1986 when her Union representative told her she could file a grievance. The grievor filed her complaint on March 4, 1986 well within the 20-day time limit for doing so. 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. Having found the Board was correct in its interpretation of the collective agreement, i~ is not necessary for us to decide whether this · application would also have failed if it could be said that the interpretation placed on the agreement by the Board was not patently unreasonable. The application is dismissed with costs to the Union. At p.706, O'Leary J. stated: In arriving at its decision, the Grievance Settlement Board accepted that the time limits set out in Article 27 are mandatory. It noted that because of the words of Article 27,8.1 and 27.8.2, a union grievance must be filed with 30 days and 60 days, respectively, "following the occurrence or origination of the circumstances giving rise to the grievance". The Board noted that under those articles, time begins to run when the complained-of event occurs whether or not the Union is aware' of the occurrence. "There is not subjective component", said the Board. But the Board found that when Article 27.2.1 states that the employee "who believes he has a complaint or a difference" shall raise it with his supervisor "within twenty (20) days of first becoming aware of the complaint or difference", the time for filing the grievance only begins to run when the employee has knowledge or awareness that there has been a violation or possible violation of the provisions of the collective agreement. The Board said that "Article 27.2.1 contemplates the knowledge on the part of the employee - a subjective concept". The court has explained in the endorsement made after the hearing before us, and set out above, why we are in agreement with the interpretation placed on the collective agreement by the Board. If the Board is correct in its interpretation of the words found in Article 27.2.1, the application for judicial review fails whether, in making its decision, the Board was deciding as to its jurisdiction or only deciding an issue within its jurisdiction. 2. At p.712-13, Saunders J. (concurring) stated: 3i In arriving at its conclusion, the Grievance Settlement Board (the Board) made two findings of fact. It found: (1) that the grievor first became aware of her right to file a grievance on February 25, 1986; and (2) that prior to that date, the grievor had neither the know]edge nor the belief that her concerns were amenable to resolution under the collective agreement. There was no attack on those findings. From them, it follows, in my opinion, that on February 25, 1986, the grievor first became aware of the complaint or difference between the parties arising from the interpretation, application, administration or alleged Violation of the agreement. Accordingly, her grievance was in time. 3. We conclude, on the evidence of the Grievor, that he was unhappy when he received Mr, Wallen's letter of November 30, 1990 (Exhibit 3) informing him that he had not been selected for an interview. He was, at that time, in a position similar to that of the Grievor in Cameron, who would have no reason to believe she had a complaint, as is referred to in article 27.2.1, until her union representative told her that she could file a grievance on February 5, 1986, which she filed on March 4, 1986, within the 20-day time limit for doin9 so. 4. In the case before us, on the basis of the the Grievor's evidence, he did, in January of 1991, have a belief that the actions of the Program Committee in denyint him an interview were, at least in part, based on his colour. Although he was somewhat uncertain as to when he raised these concerns with the Union, his evidence was that this had taken place shortly after his 32 communicating with Mr. Curling in January of 1991, and he testified that, at that time, he had received advice that he could file a grievance based on a violation of the non-discrimination provisions contained in article A.1 of the collective agreement. 5. The explanation of the Grievor for delaying his filing a grievance until June 19, 1991 was because it was only late in May of 1991, when he met with Mr. Small and received the two documents above referred to: the evaluation of the Grievor by Mr. Small 'and the memorandum of November 19, 1990 from Ms. Doherty to the selection committee concerning the Grievor, which was attached to Exhibit 8, that he realised that he had a grievance based on discrimination based on his race. in Mr. Whitaker's letter to Ms. Ravenscroft of November 12, 1991 (Exhibit 8), the following statement appears: "The content of the Memorandum is inconsistent with Mr. Lumley's most recent PPRs and we say that in the circumstances, Mr. Lumley has been discriminated against on the basis of his race contrary to article A.1 of the collective agreement." 6. Mr. Lumley's evidence that he first formed the opinion that article A.1 had been violated between the time he met with Mr. Small and the date of his meeting with Ms. Doherty is inconsistent with his earlier evidence. It appears that he had, by the time he met with Mr. Curling, or at least by the time when he met with the Union officers following his meeting with Mr. Curling, a then 33 unsubstantiated belief that he had been denied an interview because of his race. That is, sometime in January of 1991 ~he believed that he had a complaint based on a violation of the collective agreement even if it was based on incomplete evidence. And in January of 1991 he was advised that ha could file a grievance claiming a violation of article A.1 but he apparently wished to investigate the matter further before doing so. These investigations led to his receiving the two documents from Mr. Small on May 31, 1991. Unlike the situation in Cameron, where the g~ievor first became aware that she had a complaint based on a "violation or possible violation of the collective agreement" at a time within the 20-day time limit when she filed her grievance, the Grievor, here, believed that he had such a complaint in January of 1991, a time well outside the 20-day time limit for filing his grievance, 7. The significant date when time begins to run for the purpose of article 27.2.1 is not'when a grievor has satisfied him or herself that there is hard evidence to support the complaint, but when a grievor "became aware of [his or her] right to file a grievance .... " (See judgement of Saunders J. in Cameron at p.712.) It is sign.ificant that Saunders J. agreed with the conclusions of the Board in Cameron that "the significant date is when a grievor had knowledge or belief that his or her concerns were amenable to resolution under the collective agreement." 712). Here, the Grievor's evidence indicated that he had, in January of 1991, a belief that his fai}ure to be interviewed for 34 the position was based on racial discrimination and that it was amenable to resolution under the collective agreement. 8, Because the test as to when time starts to run is based oD subjective rather than objective factors does not detract from the fact that in order for an employee to believe that he or she has a complaint or difference it is not necessary that the belief be supported by a particular kind of evidence. 9. If the 9rievance arises directly from Mr. Wallen's letter of November 30, 1990 (Exhibit 3), when the Grievor was informed that he was not selected to proceed to the next phase of the selection process, then we would conclude, employing the subjective test in Cameron, that time started to run under article 27.2.1 when Mr. Lumle¥ became aware of his right to file a grievance, sometime in January (or, at the latest February) of 1991. The delay in filing the grievance until June 19, 1991 exceeded by a considerable margin the period that the collective agreement commands and, in the absence of any other submissions the grievance would be inarbitrable. 10. In Re Texaco Canada Ltd. and Oil, Chemical and Atomic Workers International Union. Local 9-599 (1978), 19 L.A.C. (2d) 369 (Baum), the grievor had been terminated as of April 30, 1977, and filed a grievance on May 11, 1977, in which he grieved: ... termination of employment from Texaco Canada Ltd. My treatment and termination by the company is unjust, 35 discriminatory, in violation of my seniority rights and is because of my union activities and membership. 11. At p.372, in dealing with the employer's argument ~hat the grievance was out of time and, hence, inarbitrab]e, the board stated: If the grievance arises directly from the letter of termination, there is no doubt that a significant de]ay resulted. It is a delay that exceeds by considerable margin that which the collective agreement commands in terms of filing a grievance. If we were to pass on the letter of termination as such there is no question that the grievance would not be permitted to go to arbitration. 12. At p.373, the board found: There is nothing in the letter of termination that gives a hint of discrimination. Rather, the grievor seems to be saying that he discovered an intent on the part of the employer to discriminate against him for, among other reasons, his activity in the union. The letter of termination was merely the culmination of that intent. Put somewhat different]y, the grievor found that the employer tended to discriminate against him for, among other reasons, union activity after the letter of termination was sent and proximate to the time when the grievance was filed. In the result, we take the view that the grievance itself must be read for the purpose of determining whether the time requirements of the collective agreement were met. The grievance, on its face, speaks of an intent to discriminate against Mr. St. Louis for, among other reasons, his union activity. It is such discrimination that frames the basis of the grievance, and not the letter of termination as such. Accordingly, it is our holding that to the extent the union is able to demonstrate knowledge on the part of the grievor concernin9 the alleged discrimination arising after the letter of termination was sent and proximate to the filing of the grievance, we will permit the matter to be heard. 36 The board concluded that their decision was based on the collective agreement and on its exercise of discretion within the meaning of s.37(5a) of the Labour Relations Act. 13. Although the board in Texaco Canada referred to its jurisdiction under 37 (5a) of the LaboDr Relations Act, its other comments are helpful in this case. In the case before us, it is evident from the Grievor's testimony, and from his memorandum of June 5, 1991 to Superintendent Doherty and Senior Assistant Superintendent Small, what the nature of his complaints were in the grievance that was ultimately fi]ed on June 19, 1991. The first four statements are clearly related to the Grievor's having been rejected as a candidate for the Management Development Program. As we have already found, the Grievor had concluded that the failure to afford him an interview was based on discriminatory motives, by January or February of 1991, although he did not then have what he regarded as conclusive evidence to support his conclusion. We have already stated that, subject to our consideration of the submission made by the Union based on waiver, the grievance as it relates to the first five matters referred to in Exhibit 4 would be out of time and inarbitrable.- Parts of item 5 and items 6 and 7 do not necessarily relate only to the allegedly discriminatory actions of the Employer in refusing to grant an interview to the Grievor for the Management Development Program position. Although the complaints contained in 37 parts of item 5 and in items 6 and 7 of Exhibit 4 appear to have been grieved in a timely fashion, the particulars contained in Mr. Whitakers's letter of November 19, 1990, set out at p. 3 above, were limited to Mr. Lumley's claim that he was discriminated against "on the basis of his race" in not having been granted an interview for the amnagement development assignment. DISCB$SION OF TRE WAIVER ARGUMENT OF TME UNION 1. On the facts before us it is evident that the Employer did not raise its timeliness objection until after the completion of the grievance procedure and after the grievance had been referred to arbitration. In fact, the objection based on timeliness was only raised on May 25, 1992, after the second scheduled date for the commencement of the hearing. The position taken on behalf of the Employer was that it was not in a position to fully appreciate the nature of the grievance until the position of the Union was explained at the commencement of the hearing on August 24, 1992. 2. We take it that the position of the Employer was based, in part, on the fact that its knowledge with respect to the the nature of the Grievor's complaint as it was not raised with his supervisor, as is required by article 27.2.1, although this was not used as a basis for objecting to arbitrability. We also take it that the knowledge of the Employer was also limited by the fact that there was no real meeting between the Grievor and the designee 38 of the Deputy Minister pursuant to article 27.3.3 of the collective agreement (Stage II). The actions ogrievance was enough to fix the Employer with notice of all relevant facts relating to any procedural defects, and that bY permitting the matter to be processed to arbitration, management must be deemed to have waived its right asis of the complaint. 3. In order for waiver to be found, we must be satisfied that the Employer understood that it had a basis for raising a procedural objection to arbitrability based on timeliness. Counsel for the Union suggested that the filing of the grievance was enough to fix the Employer with notice of all relevant facts relating to any procedural defects, and that by permitting the matter to be processed to arbitration, management must be deemed to have waived its right to object to arbitrability based on the alleged failure on the part of the Grievor to adhere to the mandatory time limits. The circumstances where waiver will be found, as set out in the cases relied by the Union, are not in dispute. In Fun~/Anand, the Board stated, at p.ll, in enunciating the principle: ... that an objection based on non-compliance 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 that case, the Board found, at p.11: ... 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 39 reply subsequent to the stage two meeting, it is clear that a timely objection to the failure to comply with th~ time limits of the collective Agreement was not made and that a fresh step was taken prior to the timeliness objection being raised. Further at pp.ll-12, the Board concluded: Once a timeliness objection has been waived it cannot be revived by notice. 4. As noted, counse] for the Union also relied on the statement contained at p.ll of Fung/Anand that the filing of the grievance fixes the parties with knowledge of the facts relating to the timeliness of the grievance: 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 To~n of Pembrok~ 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'. 5. In the Town of Pembroke case, the statement, apparently relied upon in the Fung/Anand case is found at p.128: It appeared from the evidence that the corporation had not raised the procedural objection that the grievance was out of time at any prior step of the grievance procedure, had resisted the grievance on its merits only through its entire history to arbitration and that the first time the corporation raised the procedural objection was at the hearing held by this board. The corporation's explanation that it did not realize the grievance was out of time until the night before the hearing cannot alter the position that it was fixed with knowledge of the untimeliness of the grievance when it was first instituted and at every step of the grievance procedure thereafter. 6. In t. he Town ~f Pembroke case, at p.128, the board found that: "It is apparent that the 9rievor failed to invoke step I within 4O three days of the last causal date." We do not regard the board in Town of Pembroke to have made a general statement concerning the time that an employer is fixed with notice, but it was referring to the time that the employer in that case was fixed with knowledge, based on the fact that the failure to invoke a necessary step in the grievance procedure was "apparent." 7. On the facts of the case before us, there being no evidence that a discussion of the grievance took place between the Grievor and his supervisor, as is required by article 27.2.1 and, because it appears that the meeting contemplated by article 27.3.3 was not held, the Employer would not have the usual opportunity of obtaining evidence that might bear on the timeliness of the grievance ~o as to make an early objection. In the case before us, the position of the Employer was that it did not have the information necessary to raise an objection until the commencement of the hearing, and, accordingly, it ought not to be held to have waived its right to object to the arbitrability of the grievance on the basis that it was out of time. Its succinct position, was that it ought not to be held to have waived a right it could not know it had. 8. We would have had some sympathy for the Employer's argument but for the existence of Exhibit 4. In that exhibit, entitled "Complaints against the Ministry of Correctional Services," given to Superintendent Doherty and Senior Assistant Superintendent 41 Sma]], the allegations of discrimination are set out in seven numbered paragraphs. The first four of which clearly relate to the Management Development Program and the fifth allegation apparently relates to it, at least in part. 9. It is apparent from Exhibit 6 that Superintendent Doherty was aware of what transpired at the time the second stage meeting was supposed to have been held, and we must a~sume that she was aware of the filing of the grievance on June 19, 1991. At that time, as representative of the Employer, she had knowledge of the facts that would have enabled the Employer to raise its procedural objection to arbitrability. Nevertheless fresh steps were taken. Exhibit 6, notwithstanding the absence of a meaningful meeting at Stage II, resulted in a decision being made, on the merits, to deny the g~ievance. There was no suggestion, until May 25, 1992, that an objection based on timeliness was being raised. In the circumstances, we must find that the objection was waived and the grievance is arbitrable unless the further objection to our jurisdiction is allowed. ARGUMEN~ OF THE EMPLOYER BASED ON THE PROVISIONS OF SECTION 18 OF THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT 1. It was the further position of the Employer that the grievance dealt with an al]~egation that the Grievor had not been furnished an opportunity to participate in the Metro Region Management 42 Development Program designed to give employees in the bargaining unit management training opportunities. It was stressed that approximately 70 employees applied to participate in the Program and only eight ~r nine were chosen. The persons chosen were given an opportunity to function on a temporary basis in a management position on a time limited basis. The first point made by the counsel for the Employer was that the subject of which bargaining unit employees would be given a training and development opportunity in these circumstances was not for the Board to determine but was an exclusive management right. 2. The second facet of this objection was that a promotion out of the bargaining unit was not a matter within the collective agreement and, hence, not arbitrable. The process followed by the committee involved in making selections for participation in the Program related to positions that were not within the collective agreement. 3. The third facet of this objection was that article A of the collective agreement did not deal with discrimination by one employee against another. What the article was said to deal with was discrimination by the Employer as it related to carrying out its obligations under the collective agreement. 4. Reference was made to article 27.16 of the collective agreement: 43 The Grievance Settlement Board shall have no jurisdiction to alter, change, amend or enlarge any provision of the Collective Agreement. 5. Counsel for the Union relied upon Fl%nh et al, 22/B8 (Kennedy). In that case, the nine grievors, who were employed by the Ministry of Health in the classification of Ambulance Officers in the Ottawa area, whose positions were identified in the legislation and regulations governing Ambulance work as "driver Attendant," filed grievances in late January 1988, as follows: I grieve that I/or my qualifications have been improperly appraised, and I have been denied the opportunity to do Employer sponsored training in a discriminatory manner affecting my classification and future wages. Settlement desired: That i be allowed to upgrade my job skills through the 8 hour heart aid 1000 course. In that case, the employer also raised a preliminary objection to the jurisdiction of the Board and the arbitrability of the grievance (at pp.5-6): Simply stated, the argument of counsel for the Employer in support of the preliminary objection was that the grievance did not raise any matter covered in the collective agreement; it did not raise any matter pursuant to which a right of grievance was given to an employee pursuant to Section 18(2) of the Crown Employees Collective. Bargaining Act, R.S.O. 1980, c. 108, and the only issue that it did appear to raise was one relating to training and development which, by the specific provisions of Section 18(1)(b), was an exclusive function of the Employer and could not be the subject of collective bargaining or come within the jurisdiction of the Grievance Settlement Board. With each one of those contentions we would agree. The relevant section 18 reads as follows: 18. (1) Every collective agreement shall be deemed to provide that it is the exclusive function of the employer to manage, which function, without 44 limiting the generality of the foregoing, includes the right to determine, (a) employment, appointment, complement, organization, assignment, discipline, dismissal, suspension, work methods and procedures, kinds and locations of equipment and classification of positions; and ~b) merit system, training and development, appraisal and superannuation, the governing principles of which are subjec~ to review by the employer with the bargaining agent, and such matters will not be the subject of collective bargaining nor come within the jurisdiction of a board. (2) In addition to any other rights of grievance under a collective agreement, an employee claiming, (a) that his position has been improperly classified; (b) that he has been appraised contrary to the governing principles and standards; or (c) that he has been disciplined or dismissed or suspended from his employment without just cause, may process such matter in accordance with the grievance procedure provided in the collective agreement, and failing final determination under such procedure, the matter may be processed in accordance with the procedure for final determination applicable under section 19. 6. Further, at p.6, of the Flinch case, the Board stated: It is quite true that the grievance has been drafted with a view to giving the appearance of jurisdiction by the references to appraisal, classification and discrimination. Notwithstanding the use of that language, however, it is clear that the sole issue between the parties is that the Grievors have not been permitted to take a specific training course, and the 45 only relief requested is that they be allowed to take that course. We cannot conceive of any issue that is more clearly and exclusively an issue of training and development, which by reason of the specific provisions of Section 18(1) cannot come within our jurisdiction. If authority were needed, reference can be made to OP~EU Union Grievance 672/84 (Palmer) and Brick and Roth 244/82 (Roberts). ARGUMENT OF THE UNION WITH RESPECT TO THE EMPLOYER'S SUBMISSION THAT iT NAD UNFETTERED DISCRETION WITH RESPECT TO THE SUBJECTS OF TRAINING AND DEVELOPMENT UNDER~ SECTION 18(1)(b) OF THE CROWN EMPLOYEES' COLLECTIVE BARGAINING ACT 1. It was the position of the Union that the word "board" found at the end of article 18(1) refers to the "board of arbitration" referred in s.ll(1) of the Act which is as follows: 11.-(1) Upon written notification by the Tribunal, each of the parties shall, within ten days of the notification, appoint to a board of arbitration a member who has indicated his willingness to act and shall each notify in writin9 the other party and the Tribunal of the name and address of the member so appointed. 2. It was also the position of .the Union that a violation of article A.1 represented a breach of the collective agreement and that this board had a right, and obligation, to adjudicate a grievance based on a violation of that article under s.19(1) of the Act: 19.-(1) Every collective agreement shall be deemed to provide that in the event the parties are unable to effect a settlement of any differences between them arising from the interpretation, application, administration or alleged contravention of the agreement, including any question as to whether a matter is arbitrable, such matter may be referred for arbitration 46 to the Grievance Settlement Board and the Board after giving full opportunity to the parties to present their evidence and to make their submissions, shall decide the matter and its decision is final and binding upon the parties and the employees covered by the agreement. Counsel for the~ Union relied on ~_laine Warden, 1152/87 (Dissanayake),at p. 1, where the Board had to deal with an objection to arbitrability based on the position that the grievance did not allege the breach of any provision of the collective agreement or the Act, that would give the Board jurisdiction to entertain it '. He submitted that the grievance is an attempt to challenge the employer' s conduct relating to staff complement and job assignment which pursuant to section 18(1) of the Act are clearly exclusively management rights which are not subject to collective bargaining or to the jurisdiction of this board. Counsel for the grievor in the Warden case argued that the grievance, in that case, was based on article 18.1 of the collective agreement which, in part skates that: "The Employer shall continue to make reasonable provisions for the safety and health of its employees during the hours of their employment." The Board's ruling on the preliminary objection at pp.2~3, Nas: The Board agrees with counsel for the grievor that it is not essential that the grievance refer specifically to a particular article in the collective agreement or provision in the Act before it becomes arbitrable. Nor are we unduly concerned that the grievance did not use the phrase "health and safety" and did not articulate a health and safety issue precisely. In that we recognize that grievances are not written necessarily by legally trained persons, the Board will not refuse to accept a 47 grievance merely because of technical defaults or imprecise language. All that is required is that the true nature of the grievance must be communicated to the employer. The Board does not agree with the employer that in all cases the employer has an unfettered right to exercise its management rights in any manner it sees fit. These management rights may be restricted expressly or implicitly by other provisions of the agreement. Specifically, we find that the employer may not exercise a management right in such a manner as would put at risk the employees' health and safety, because that would be' contrary to article 18.1. If the thrust of a grievance is a health and safety issue under article 18.1, then in our respectful view that grievance is arbitrable despite the fact that the resolution of that grievance may necessitate an inquiry relating to the employer's exercise of management rights. 3. It was submitted on behalf of the Union that article A.1 represented an agreement of the parties to incorporate certain safeguards contained in the Qntario Human Rights Code into the collective agreement. DISCUSSION OF THE ISSUES RAISED BY THE OBJECTION TO ARBITRABILITY BASED ON TRE SUBMISSION TI~AT THE EMPLOYER BAS UNFETTERED DISCRETION WIT~ RESPECT TO THE SUBJECTS OF TRAINING AND DEVELOPMENT AND T~AT THERE IS NO STATUTORY PROVISION TI{AT ALTERS, OR ANY PROVISION IN T~E COLLECTIVE AGREEMENT THAT CAN ALTER, THE EXTENT OF ITS DISCRETION. 1. Counsel for the Employer likened the complaint of the Grievor to one where a member of mannagement had decided to take three employees in the bargaining unit to lunch but had, deliberately, not invited a fourth bargaining unit member. This decision was 48 said to have been based on a discriminatory motive, the example given being the marital status of the fourth employee. Such conduct could not amount to a violation of the collective agreement, nor should the alleged conduct of the representatives of the Employer in the case before us. The submission was that article A.1 did not expand the scope of the collective agreement. We emphasise that the Employer denies the allegations with respect to its representatives having discrimimated against Mr. Lumley aL he alleges. 2. Article A of the collective agreement did not exist in the previous collective agreement between the parties expiring on December 31, 1988. In Bousquet, 541/90 etc. (Gorsky), grievances, based in part on discrimination because of the grievor's ethnic origin, were filed under the current collective agreement. One of the grievances involved the grievor's having been denied a training and development opportunity, allegedly because he was a Francophone. Counsel in that case did not refer to the effect of article A.1, and no specific violation of article A was claimed. Nevertheless, one of the objections to arbitrability, with respect to two of the grievances, related to the grievor's "asking this Board, in effect, to enforce the provisions of the Ontario Human Rights Code S.O. 1981, c.53 (the "C~ode"). The section of the Code referred to was section 4: (4)(1) Every person has a right to equal treatment with respect to employment without discrimination because of race, ancestry ... ethnic origin (2) Every person who is an employee has a right to freedom from harassment in the workplace by the employer 49 or agent of the employer or by another employee because of race, ancestry ..· ethnic origin 3. In the Bous~uet case, the employer submitted that there was no provision in the Collective Agreement that had been violated by it, and that, accordingly, the Board was without jurisdiction to deal with the grievance alleging discrimination based on a ground prohibited by the Co~. A second objection was that it was beyond the jurisdiction of the Board to consider a grievance which, in any way, concerned the granting of training or development opportunities. 4. At p.13 of the Bousquet case, the Board stated: In carrying out legitimate government purposes the Employer would have to adhere to the public policy as enunciated in the CQd~, in particular section 4. The policy inherent in that section must be applied in ascertaining whether an employer has behaved in good faith. If the real allegation against the Employer involves a breach of the public policy inherent in s. 4 of the gode, and if the Employer is found to have discriminated against the Grievor or harassed him for any of the prohibited grounds contained in section 4, this will have a considerable bearing on finding a lack of good faith on its part in exercising its management rights under s. 18~l)(b) of the Ac~t with respect to affording training and development opportunities to employees. 5. In dealing with the second objection to arbitrability in the Bousque~ case, based on the submission that the employer had unfettered discretion with respect to the subjects of training and development and that there was no statutory provision that altered, or any provision in the collective agreement that could alter, the extent of its discretion, the Board stated at pp.67-8: 50 In rejecting the preliminary objections to our jurisdiction, we have found that the issue of good faith in the exercise of the Employer's discretion as it relates to the subjects of training and development opportunities ... are properly before the Board, and this includes the question of whether the Employer, in refusing the Grievor's requests, did so in violation of the provisions of s. 4 of the cod~. 6. The example relied upon by the Employer of a claim based on a prohibited ground of discrimination under the Code is not apt. Although we acknowledge the limitations on a grievance alleging that an employer has refused to properly consider an employee for a training and development opportunity, this does not give the employer carte blanche. There is no case which we are aware of that grants to an employer the right to carry out the management rights granted to it by statute or under the collective agreement in bad faith. Even broadly based management rights provisions which might permit management to act discriminatorily would not the right to discriminate contrary to the prohibitions of encompass the Ontario Human Rights Co~e. Cf. Re Metropolitan TorQnto Board o~ Comr's of Po]ice and Metropolitan T6ronto Police ~ss'n et al. (1981), 124 D.L.R. (~d) 684 (Ont~ C.Ao) leave to appeal to S.C.C. /J refused. 7. In the circumstances, it is unnecessary to discuss whether a grievance can be founded on a violation of article A.1. Even if article A.1 does not specifically afford an employee the right to file a grievance based on its herin9 been violated, in considering whether an employer has acted in good faith, in a claim based on 51 discrimination in the carrying out of a management function pursuant to section 18(1)(b) of the Act, the Board may examine the evidence to see whether the employer has discriminated on one of the prohibited grounds contained in the Qntario Human Rights Code. It is the substance of the grievance that we must consider and on the basis of the particulars furnished to the Employer, as set out in Exhibit 8, it is clear that the complaint concerned the failure to grant the Griever an interview, and that the complaint was based on discrimination on the basis of his race. While the particulars state that this was "contrary to article A.1 of the Collective Agreement and article A", this does not mean that the right to base a grievance on an alleged violation of the Code does not exist, even if article A.1 does not create a separate right to brimg a grievance based on discrimination for grounds prohibited under the Code. The inclusion of article A.1 did not change the obligatioJ of the Board with respect to requiring that it conside~ whether there is evidence ofacts of discrimination on prohibited grounds as set out in the ~ode, as explained in Bou~quet. In the case before us, there could have been no doubt in the minds of the representatives of the Employer about the real nature of the grievance. 8. The limitations on an employee's right of grievance with respect to such matters as training and development as set out iD s.18(1)(b) of the ~ are recognized at p.67 of Bousquet: Here, the Griever has no statutory right to grieve because he has been denied a training and development 52 opportunity. He claims that he does have a right under the collective agreement to certain consideration when he app]ies for a position under art. 4 of the collective agreement, and that any restriction on the Board's jurisdiction to deal with matters relating to training and development must be read subject to an employee's right to fair consideration under art.4. Because of the statutory limitation imposed by s.iS(1), there is no room for the penumbral activity permitted in Anderson as might arise through the operation of the statutory rights contained in s. 18(2). Here, the right to raise the subjects of training and development by way of a grievance has been restricted by means of a clear indication on the part of the Legislature. Cf. ~etro Torontq case, at p.250. The effect of the statutory limitation placed on the Board's jurisdiction differentiates this case from ~ounci~ of Printing Industrie~ and Metro The above statement, notwithstanding the breadth of the discretion granted the employer, does not enable the Employer, ia the case before us, to base its decision as to which employee receives a training and development opportunity in whole or in part on the race of an applicant contrary to the provisions of the Code. DECISION In the result, and for the above reasons, we find: 1. In accordance with the particulars furnished by counsel for the Union, the grievance is limited to one claiming that the Grievor was not granted an interview for discriminatory reasons based on his race. 53 2. Although we have found that the complaint, as stated in the reply to the request for particulars, was filed outside of the mandatory time limits provided for in article 27.2.1 of the collective agreement, and hence would be deemed to have been withdrawn pursuant to article 27.13 of the collective agreement, the Employer had', by taking a fresh step with knowledge of the facts relating to the untimeliness of the grievance, waived the right to maintain the timeliness objection. 3. We have also found that the objection based on the lack of jurisdiction of the Board to hear a grievance based on the Employer having carried out the exclusive function with respect to training and development also fails. 4. In declaring that the grievance is arbitrable, we emphasize that the claim which is arbitrable is limited by the statement contained in the particulars relating to the alleged discrimination against Mr. Lumley based on race resulting in his bein9 refused an interview for the management development assignment at Toronto East. 5. Because of our limited jurisdiction to review management's exercise of its exclusive function with respect to training and development, the evidence that we hear must be restricted to whether Mr. Lumley was discriminated against on the basis of his race. If he was, then the decision could not be said to have been 54 made in good faith. As was noted in Bousquet, however broad are management's rights with respect to carrying out the exclusive functions assigned to it under the Act, it cannot act in bad faith. Merely because the training position was a management one, does not alter the fact that the Employer, in the case before us, was determining a matter encompassed under s.18(1)(b) "training and development." The function was being exercised with respect to bargaining unit personnel under management's rights pursuant to s.18{1){b) of the Act. To allow the Employer to decide which bargining unit employees will receive training and development opportunities while engaging in discriminatory practices based on the race of employees would permit the Employer to carry out its rights in bad faith. It could never have been the intention to i~mmunize management from challenges based on making decisions founded on "discrimination practiced by reason of race, ancestry, place of origin, colour, ethnic origin, citizenship, creed, sex, sexual orientation, age, marital status, family status, or handicap, as defined in s.9(1) of the Ontario ~uman Rights Code... ." Such acts of discrimination are prohibited and cannot be equated with the kind of social discrimination used in the example given by counsel for the Employer. 6. We have requested that the Registrar schedule a date for the continuation of the hearing. 55 Dated at Toronto this 23rd day of February , 1993. M. Gorsky - Vice Chairperson ~. O'Toole - Member