HomeMy WebLinkAbout1991-1526.Union.95-09-28 ONTARIO EMPL 0 Y~S DE LA COURONNE
CROWN EMP&O YEE$ DE L 'ON TARIO
GRIEVANCE C,OMMISSION DE
SE'R'LEMENT REGLEMENT
BOARD DES GRIEFS
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GSB# 1526/91, 1294/9'2
OPSEU# MBC-U474, MNR-U628
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
TH~ GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Union Grievance)
G~ievo~
- &nd -
The Crown in Right of Ontario
(Ministry of Natural Resources/
Management Board of Cabinet)
Employer
BEFORE: W. Kaplan Vice-Chairperson
M. Vorster Member
F. Collict Member
FOR THE H. Law
GRIEVOR Counsel
Ontario Public Service Employees Union
FOR THE - P. Toop
EMPLOYER Staff Relations Officer
Management Board of C~binet
FO~ THE P. Straszynski
THIRD PARTIES Counsel
Torkin, Manes, .Cohen & Arbus
Barristers & Solicitors
HE~tRING July 8, 1992
February 4, 1993
May 14, 1993
June 24, 1994
December 16,. 1994
Introduction
On August 6, 1991, OPSEU filed a union grievance (the "1991 Grievance")
with Management Board of Cabinet alleging a violation of Article 25 of the
Collective Agreement. In brief, the union claimed that the employer was
improperly calculating the continuous service of a large number of civil
servants employed by the Ministry of Natural Resources. The case
proceeded to a hearing in Toronto, at which time submissions and
arguments were heard, and an agreed statement of fact was introduced into
evidence. A number of procedural issues were also raised, and in our
decision dated March 18, 1993, we set out in some detail the background to
the dispute between the parties, the issues in dispute, and the reasons for
our ruling ordering the consolidation of the 1991 Grievance with another
grievance filed on July 9, 1992 (the "1992 Grievance"). The merits of these
two grievances, both alleging a violation of the seniority calculation
provisions of two successive collective agreements, were addressed at a
hearing held on May 14, 1993. At that time, the Board heard argument from
the parties as well as from two of a large number of the third parties
present at the hearing.
In the aftermath of that hearing, the 8oard received written
representations from Mr. Irv Kleiner, a lawyer at a Toronto law firm who
had been retained by one of the third parties, Mr. Mark Reynolds. In his
letter, Mr. Kleiner took issue with the sufficiency of the notice provided to
Mr. Reynolds and other third parties. The Board was asked to reopen the
hearing in order to provide Mr. Reynolds and other third parties with
meaningful notice and a real' opportunity to participate.
Having received .this letter, the Chair of. this panel of the Board directed the
Registrar to send a copy of Mr. Kleiner's letter to union and employer
counsel. This was done by letter dated June 16, 1993. By letter dated June
9, 1 993, and by letter dated June ;)1, 1993, both employer and union counsel
consented to the reopening of these proceedings in order to ensure that the
third parties were not deprived of any possible participatory right.
Out of an abundance of caution, and in deference to the wishes of the
parties, the Board, for reasons set out in another interim decision dated
July ;)0, 1993, agreed to direct the Registrar to schedule the case for
rehearing.
That rehearing began on June Z4, 1994. For reasons which need not be
addressed in this award, only union counsel presented his argument that
day. At the Board's direction, the proceedings were adjourned in order to
allow Mr. Peter Straszynski, an associate of Mr. Kleiner now representing
Mr. Reynolds and a number of the other third parties to call Mr. Brent Gibbs.
When the hearing reconvened on December 16, 1994, Mr. Gibbs testified.
Employer counsel' then presented his argument, followed by the lawyer
representing the third parties. As is customary, the union was given the
final right of reply.
There is no real dispute about the facts of' this case, and as already noted,
they are set out in our earlier award. Very briefly, on behalf of a large
number of seasonal employees working for the Ministry of Natural
Resources, the Union, in 1990, filed a.grievance. As a result of that
grievance a Memorandum of Settlement, also known as the "roll-over
agreement," was reached. The settlement provided, among other things, for
those employees to "roll-over" into the classified service. The settlement
also provided a formula for the calculation of their seniority. The formula
provided for a more generous seniority caicul'ation for roll-over employees
than for seasonal employees who had won job competitions and in that way
entered the classified ranks. In 1991, the union filed a grievance taking
issue with the seniority calculation. That grievance, the 1991 Grievance,
was filed under the Collective Agreement dated January 1, 1989 to
December 31, 1991. In 1992, the union filed an another grievance; the 1992
Grievance, under the new Collective agreement dated January 1, 1992 to
December 31, 1993. As already noted, we ordered the consolidation of
these two grievances in our earlier award, having reached the conclusion ~
that they raised similar issues of fact and law, and having found that there
were a number of other, reasons in support of their consolidation.
The union takes the position that the provisions of the 1992-1993
Collective Agreement retroactively readjusted the seniority of the
roll-over employees by providing a' new, and common, basis for the
calculation of the seniority of all employees. :.The employer takes the
position that the Memorandum of Settlement was not affected by the new
Collective Agreement, and that being the case, both the Memorandum of
Settlement and its results should not be interfered with.
When the case reconvened on June 24, 1994, Mr. Straszynski made some
submissions to the effect that the case was inarbitrable because the issue
to be determined, namely the seniority of the rollover employees, had been
finally and fully resolved by the Memorandum of Settlement. As this
preliminary objection was so obviously intertwined with the merits of the
matter in dispute, the Board ruled that the case should proceed in the
6
normal, way, noting-at the time that this case was not about some
settlement document being considered in isolation; rather, the issue that
was raised was whether the negotiation of a new collective agreement
amended a provision of a previous Memorandum of Settlement. Put another
way, there is a simple question to be answered in this case:. On what basis
is the seniority of the rollover employees calculated? By the formula set
out in the Memorandum of Settlement, or by the provisions of the
1992-1993 Collective Agreement?
B.efore turning to the agreed facts, evidence, and submissions of the
parties, it is useful, to once again set out the releVant provisions of the two
Collective Agreements in issue in this case.
,'
Article 25. 1 of the January 1, 1989 to December 31, 1991 Collective
Agreement provides:
SENIORITY (LENGTH OF CONTINUOUS SERVICE)
25. 1 An employee's length of continuous service will
accumulate upon completion of a probationary period of
not more than one (1) year and shall commence:
(a) from the date of appointment to the Classified
Service for those employees with no prior service in the
Ontario Public Service; or
(b) from the date on which an employee commences a
period of unbroken, full-time service in the public
service, immediately prior to appointment to the
Classified Service; or
(c) for a regular part-time civil servant, from January 1,
1984 or from the date on which he commenced a period
of unbroken, part-time service in the public service,
immediately prior to appointment to a regular part-time
position in the civil service, whichever is later..
"Unbroken service" is that which is not interrupted by
separation from the public service; "full-time" is
continuous employment as set out in the ours of work
schedules for the appropriate classifications; and
"part-time" is continuous employment in accordance with
the hours of work specified in Article 61.1.
Article 25.1 of the January 1, 1992 to December 31, 1993 Collective
Agreement provides:
SENIORFDY (LENGTH OF CONTINUOUS SERVICE)
Effective February 3, 1992, an employee's length of
continuous service will accumulate upon completion of a
probationary period of not more than' nine (9) months and
shall commence:
(a) from the date of appointment to the Classified
Service for those employees with no prior service in the
Ontario Public Service; or
(b) effective January 1, 1992, from ithe date established
by adding the actual number of full-time weeks worked
by a full-time unclassified employee during his full-time
employment back to the first break :in employment which
is greater than thirteen (13) weeks; or
(c) for a regular part-time civil servant, from January 1,
1984 or from the date on which he commenced a period
of unbroken, part-time employment ,in the public service,
immediately prior to appointment to a regular part-time
position in the civil service, whichever is later; or
(d) effective January 1, 1984, from the date established
by adding the actual number of full-time weeks worked
by a full-time seasonal employee during his full time
employment back to the first break .in employment which
is greater than thirteen (13) weeks.
"Unbroken service" is that which is not interrupted by
separation from the public service; "full-time" is
continuous employment .as set out in the ours of work
schedules for the appropriate classifications; and
"part-time" is continuous employment in accordance with
the hours of work specified in Article 61.1.
Effective December 20, 1990, any leaves-of-absence
granted under Articles 3.9 and 3.35 shall be included in
the calculation of length of continuous service.
It is also worthwhile to set out the terms of the Memorandum of
Settlement signed by the parties resolving the'1990 grievance:
In full and final settlement of the above-captioned
grievance, the parties agree as follows:
1. The Ministry shall identify to the Union all Group 3
positions of a least 43 week[s] duration and shall also
identify any and all current incumbents.
2. The Ministry shall appoint all of the current
incumbents of positions of 43 weeks or longer duration,
provided they have completed at least two seasons of
employment as a seasonal unclassified employee, or have
been incumbent in the position for the last 52 weeks of
active employment, to the classified civil service
effective the date of this settlement.
3. The Ministry shall calculate each incumbent's length
of continuous service as a classified civil servant by
crediting each incumbent with seniority accumulated
under article 3.20.1 of the collective agreement, to be
pro-rated as calendar rather than hourly service, thus
providing a calendar date of .continuous service, based
upon hours per day on the appropriate schedule.
4. The Ministry shall, upon having implemented
paragraphs ?_ and 3 above, apply article 24 of the
collective agreement to all incumbents identified under
paragraph 2 and these incumbents shall also have the
benefit of the job security guarantees provided by the
Ministry pursuant to the Deputy Minister's bulletin dated
May 21, 1991.
.5. The Ministry agrees that positions identified as 43
weeks or longer, but which have no .incumbent who shall
be appointed tO the civil service pursuant to paragraph 2,
shall be posted in accordance with article 4 of the
collective agreement or staffed in accordance with other
procedures agreed to by the parties or deleted. Posted
positions will contain an area of search allowing
applications only from current classified and
unclassified staff within the Ministry.
6. The Ministry and the Union agree to appoint an equal
number of representatives to a joint committee to
resolve anomalies flowing from this settlement where
the duration of the position or tenure of the incumbent is
unclear or in dispute. The parties further agree that
there shall be full disclosure of all relevant information
to facilitate this committee's operation.
7. Any dispute that is not resolved by the joint
committee under paragraph 6, above, may be advanced by
the Union directly to step 3 of the grievance procedure as
a means of speeding resolution.
8. The Ministry agrees that seasonal unclassified
positions shall not be of 43 weeks or more duration
followed by nine or less weeks inactive employment in
any twelve-month period. The Union agrees that the
positions below 43 weeks per year are properly
characterized as seasonal in nature.
9. In the event that the Ministry does not adhere to
paragraph 8 above, the provisions of this settlement
shall apply. However, the parties may agree mutually to
alternative remedies.
10..The Ministry and the Union agree that this
settlement shall be communicated to Ministry staff by
way of simultaneou~ communications.
11. This settlement shall be made an order of the
Grievance Settlement Board after the issuance of the
communications in paragraph 1.0 above.
12. The grievance is withdrawn.
Agreed Facts
Virtually none of the facts in this case are in dispute, and all the relevant
facts are set out in our earlier awards. At the commencement of the
hearing on' May 14, 1993, there was a dispute between the parties about the
employer's request to call bargaining history, evidence. The Board heard
lengthy argument from both parties on this point, and ultimately it was
decided by the parties that this evidence was not necessary as the parties
were agreed that neither the union nor the employer raised either the 1990
Memorandum of Settlement or the 1991 Grievance taking issue with the
employer's seniority calculations in the negotiations leading to the signing
of the 1992_-1993 Collective Agreement.
At the commencement of the hearing on June 2:4, 1994, the Board was
advised that the parties had agreed to a number of additional facts, and
some evidence was also subsequently led.
Additional Agreed Facts
1. The effect of an oVerride on the rollover agreement by the new provision
of the Collective Agreement 'would be substantially detrimental to the
seniority rights of most employees covered by the Memorandum of
Settlement,
2. The Memorandum of Settlement has been implemented from the time of
its signing to the present.
3. There is now less job security in the bargaining unit as a result of
downsizing. There has been a significant rise in the number of notices of
layoff to both classified and unclassified employees. The union has
negotiated some improvements to the job security provisions to deal with
these layoff notices.
4, If Article 25.1 of the 1992-1993 Collective Agreement were applied to
Mr. Reynolds, his continuous service date would change from March 18, 1986
to May 13, 1990, with a corresponding effect on his entitlement to benefits.
For example, his current vacation entitlement of four weeks per year would
be reduced, and would not be recovered until 1998. His retirement date, in
another example, would be delayed by two years.
The Evidence
Mark Reynolds testified. Mr. Reynolds, 41, told the Board that he began
work for the Ministry of Natural Resources in the summer of 1983. He is
one of the employees covered by the Memorandum of Settlement. According
to Mr. Reynolds, the rollover agreement has had a profound effect on his
life. It gave him job security and a better retirement package, and it
significantly improved his benefits, such as paid vacations and life
insurance. Mr. Reynolds believed that the Memorandum Of Settlement was
permanent and binding. No one ever told him, :prior to the filing of the
second grievance, that the effect of Article 25 in the new collective
agreement might be to rescind the benefits obtained from the Memorandum
of Settlement. Mr. Reynolds was aware of the August 1991 grievance, and
testified that he understood that the purpose of this gr!evance was to
provide benefits to the covered positions.
As already noted, Mr. Gibbs testified. In January, 1992, Mr. Gibbs was
Director, Employee Relations Branch of Management Board Secretariat and
was involved in the negotiations leading to the 199Z-1993 Collective
Agreement. He is also the author of a Memorandum dated June 8, 1992,
reproduced in its entirety below. He testified that he wrote this"
Memorandum because of some difficulties with the union's interpretation of
Article 25.1, and did so in an attempt to clarify some of these
misunderstandings - several of which he explained in his evidence. He told
the board, however, that he did not consider the position of the roll-over
employees when he wrote the Memorandum, and was of the view that the
result of his memorandum would be to increase the seniority of employees,
not decrease it. According to Mr. Gibbs, he reviewed the Memorandum with
OPSEU's Chief Negotiator before issuing it.
Union Argument
The union argued that this case concerns a problem of two-tiered seniority:
Union counsel noted that two employee~,, each with exactly the same length
Of service, could have different seniority dates depending on whether they
rolled-over or posted in to the classified civil .service. In most cases,
counsel noted, the seniority formula set' out in the Memorandum of
Settlement providing for the rollover of seasonal employees has resulted in
those members of the bargaining unit obtaining greater seniority than
employees, who posted in to the classified ranks even if the actual time
spent on the Ministry payroll was exactly the same.
In the union's submission, it was absolutely clear that Article 25.1 of the
1992-1993 Collective Agreement superseded the earlier Memorandum of
Settlement establishing, as it did, a uniform seniority calculation formula
for every member of the bargaining unit. Counsel noted that for a number of
years unclassified employees who successfully entered the classified ranks
had their seniority calculated by terms of what was Article 25.1 of the
1 989-1991. Collective Agreement. The result of the employer's application
of this provision, counsel argued, was to limit seniority credit for these
employees to their last seasonal contract - usually, a period of
approximately 11 months. On October 30, 1990, the union filed a grievance
taking issue with this interpretation and, more generally, with .the status
of the seasonal employees. Counsel pointed out that the Memorandum of
Settlement was negotiated in response to this grievance, and it resulted in
the roll-over of some 900 seasonal employees in the classified ranks. By a
term of that Memorandum of Settlement, the parties agreed that the roll-
over employees would have their seniority calculated using an hourly
formula, retroactive to January 1, 1984. The .Memorandum of Settlement
was reached on June 13, 1991. On August 6, 1991, the 1991 Grievance was
filed.
In the union's submission, the purpose of that grievance was clear: to
remedy the-imbalance in seniority calculation, resulting from the
application of a different formula to the roil-over and posted in employees.
in the aftermath of this grievance, counsel observed, the parties entered
into negotiations for a new Collective Agreement, and changes were made
in the 1992-1993 Collective Agreement to Article 25.1. The fact that
these changes were made was, counsel argued, suggestive of the parties'
recognition that seniority was both an absolute and a relative concept, and
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that it is therefore necessary for all employees to have .their seniority
calculated by the same measuring stick. The fact that the 1991 Grievance
was outstanding was an important factor to be kePt in mind for it was a
necessary part of the overall context in which the collective bargaining
negotiations took place. Counsel argued, very simply, that the parties were
aware of the problems which resulted from the implementation of the
Memorandum of Settlement, and the fact that a grievance had been filed
with respect to it, when they entered the negotiations leading to the
1992-1 993 Collective Agreement, and the new provisions of Article 25.1.
Turning to that Collective Agreement, counsel pointed out that it is an
agreement between Management 8oard and OPSEU, and that OPSFU is
recognized in this agreement as the exclusive bargaining agent for all
public servants. Counsel argued that this being the case, the reference in
Article 25.1 to "an employee" was a reference toall employees, and was not
a reference to all employees except roll-over employees. In counsel's
submission, this provision, on its face, covered all employees, and set out
the formula to be used in calculating their seniority. Counsel suggested,
given that the employer was aware during negotiations that there was a
union grievance outstanding with respect to th'e calculation of the seniority
of employees occasioned as the result of the employer's implementation of
the Memorandum of Settlement, that if the parties had wished to exempt
the roll-over employees from the.operation of the revised Article 25.1, they
had the opportunity, in negotiations, to do so. In the .meantime, the
language of the. provision was clear, and counsel argued, that it clearly
covered all employees. Accordingly, anyone asserting a contrary provision
had, in the. union's submission, the burden of proving their case.
Counsel also argued that the very language of Article ?-5.1 indicated that it
was to apply to all employees with a retrospective effect. Counsel noted
that Article 25.1 does not say that it begins to apply on some date after the
Memorandum of Settlement was signed. Rather, it establishes, in
subsection (d), January 1, 1984 as the reference point to be used for the
calculation of seniority for seasonal employees entering the classified
service. In counsel's argument, the significance of this should not, in the
context of this case, be under-estimated. Given this earlier date, counsel
again argued that if the parties had wished to exempt the roll-over
employees and perpetuate the employer-created two-tiered seniority
system, they would have had to put some clear language to that effect in
the Collective Agreement in order to do so. And the fact is, counsel argued,
that they had not.
indeed, the union asserted that the impact of the changes to the Collective
Agreement, and the employer's understanding with respect to them, could be
seen in a June 8, 1997_ Memorandum from Brent Gibbs, the Director,
Employee Relations Branch, Management Board Secretariat, to all Ministry
Directors of Human Resources, referred to earlier in this award.
The text of this Memorandum is as follows:
ARTICLE 25 '.
SENIORITY (LENGTH OF CONTINUOUS SERVICE)
- the article affects all eligible staff automatically and
not just those who request it.
- employees appointed to classified staff from full time
unclassified staff after January 1, 1992 are eligible
under 25.1 (b).
- employees appointed to classified staff from either
regular part: time or seasonal unclassified after January
1, 1984 are eligible under 25.'1(c) and (d).
- full time unclassified employees appointed to
classified staff before January 1, 1992: and regular part
time and seasonals appointed to classified staff before
January 1, 1984 are not eligible.
- the article determines the seniority of the employee
and has nothing to do with the date of postings under
article 4 (i.e. whether the date of a competition was
before or after January 1, 1.992).
Example
1) An.employee with unbroken full time unclassified
service from May of 1988, except for one week
immediately prior to appointment to classified staff,
and who is appointed to classified staff in May of 199Z'
starts with four years of continuous service.
An employee with unbroken .full time unclassified
service from May of 1988, except, for one week
immediately prior to appointment to the classified staff
and who was appointed to the classified staff in May of
1991 has a seniority from May of 1991.
In other words, there is no retroactive application for
former unclassified staff appointed before January 1,
1992:, and for regular part time or seasonals appointed
before January 1, 1984.
In the union's submission, this Memorandum, dated some three months after
Article 2:5.1 in the 1992-1993 Collective Agreement came into effect, and
which made no mention of special treatment for roll-over employees,
indicated that the employer believed that all employees should have their
seniority calculated in the same way.
Counsel also argued that the timing of the Memorandum of Settlement was
important in this case. It was signed during the term of the 1989-1991
Collective Agreement, but before the negotiation and signing of the
1992-1993 Collective Agreement. While it was possible, in counsel's
submission, for a Memorandum of Settlement, settling a grievance, to
modify a term of a Collective Agreement, counsel argued that any such
memorandum, signed during the currency of a prior collective agreement
would not continue in effect if the language of a successor collective
agreement clearly modified its terms. Simply put, specific language in a
collective agreement dealing with a matter in dispute will, counsel
suggested, always trump some earlier settlement with respect to that
same matter where the subsequent collective agreement provision
indicates an intention that the parties wish the matter in issue to be
resolved according to different terms. In support of this proposition,
counsel cited Re International Association of Machinists. Local 386, and
Hobart Manufacturing Co. Ltd. 21 L.A.C. 141 (Johnston) where the Board
adopted, with approval, the principle that "a side agreement or letter of
understanding does not continue from collective agreement to collective
agreement unless in some way incorporated into or attached to the
subsequent collective agreement" (at 145). Counsel noted that the
Memorandum of Settlement was never incorporated or attached to any
collective agreement, and suggested that this further strengthened the
union's case.
Counsel also referred to a number of cases dealing with seniority beginning
with Arbitrator Reville's well-known Tung-Sol of Canada 15 L.A.C. 161
award:
Seniority is one of the most important and far-reaching
benefits which the trade union movement has been able
to secure for its members by virtue of the collective
bargaining process. An employee's seniority under the
terms of a collective agreement gives rise to such
important rights as relief from lay-off, right to recall to
employment, vacations and vacation pay, and pension
rights, to name only a few. It follows, therefore, that an
employee's seniority should only be affected by very
clear language in the collective agreement concerned and
that arbitrators should construe the collective
agreement with the utmost strictness wherever it is
.. contended that an employee's seniority has been
forfeited, truncated or abridged under the relevant
sections of the collective agreement (at 162).
In the .union's submission, the Tung-Sol award, among other things,
underlines the absolute importance of relative seniority - an issue, he
pointed out, of some importance in the instant case.
The union also took the position that it was important to respect the
collective bargaining decisions of the parties. In this case, that meant
giving Article 25.1 its proper interpretation consistent with
long-established and generally accepted principles of arbitral
jurisprudence. Counsel referred to Re I~iracle Food Mart and United Food &
Commercial Workers International Union. Local 175/633 21 L.A.C. (4th)433
(Marszewski), a case interpreting a provision conferring super-seniority on
a union steward. In the course of her reasons for decision, Arbitrator
Marszewski noted that, in general, arbitrators strictly construe
super-seniority provisions (at 438). Counsel suggested that if .the parties
had wished to confer super-seniority on the roll-over employees, given the
profound implications of such a decision, some specific language in their
collective agreement would be necessary to establish that such a grant had
taken place.
In conclusion, counsel argued that the evidence established that as soon as
the union was aware of the employer's interpretation and application of the
Memorandum of Settlement, it filed a grievance taking issue with the
manner in which the employer was calculating seniority. The employer
persisted, notwithstanding the union, representations on point, and the
parties were aware of this issue when they entered into the negotiations
leading to the 199Z-1993 Collective Agreement. Article 2.5.1 of that
agreement was revised, and counsel suggested that it is obvious by the
language of that provision that the parties sought, in subsection (d) to
ensure the uniform calculation of seniority for all employees. Counsel
referred to the term of the Collective Agreement, as set out in Article 86,
and suggested that this was yet another reason why the union's grievances
should prevail. There was no doubt, counsel stated, that it was well within
the parties' power to negotiate away the terms of some settlement.
Counsel noted that had Article ;~5.1 provided for a richer seniority
calculation formula, it was most unlikely that anyone would have taken the
position that the roll-over employees were ineligible because of the
Memorandum of Settlement. Such an interpretation would, counsel argued,
be complete!y inconsistent with the application of the Collective
Agreement across the bargaining unit, which is what the union sought in the
instant case.
Very simply, in the union's view, there was nothing in the language of
Article Z5.1 indicating the parties' intention to establish a two-tiered
seniority system. Counsel, therefore, asked. that the union grievances be
upheld, and that the employer be directed to recalculate the seniority of the
2O
roll-over employees in accordance with Article 25.1, and that the 8oard
remain seized with respect to the implementation of its award.
Employer Arqument
Employer counsel began his submissions by observing that this case does
not involve the interpretation of some new provision of the collective
agreement. Rather, it involves an issue fundamenta( to labour relations,
namely the sanctity of settlements willingly entered into by unions and
emPloyers. Counsel noted that the ~lemorandum of Settlement in the
instant case involved a large number of employees, and dealt with' a most
critical issue: seniority.
In the employer's view, the 1997_-1993 Collective Agreement did not
overturn the t~emorandum of Settlement, nor did it deprive the
beneficiaries of that settlement of the benefits of the deal. Not only did
the individual roll-over employees have an on-going expectation interest;
counsel argued that the parties themselves have a continuing reliance
interest in ensuring that the Settlements they reach will be maintained.
And, in the employer's view, these expectations, and this reliance, would
have been in the minds of the parties' when they negotiated the 1 992-1993
Collective Agreement.
Referring to the Memorandum of Settlement, counsel pointed out that it
begins by describing itself as the "full and final settlement of the
above-captioned grievance..." In the employer's view, these words, and the
document considered generally, evidence the parties' intention that the
settlement finally resolve certain matters in dispute and to do so in a
forward-looking way. Seniority was one of those issues, and the
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settlement provided a formula for the calculation of the seniority of the
roll-over employees. Counsel also pointed out that the Memorandum of
Settlement, and issues relating thereto, have proceeded to hearings before
the Board - at a time when the 1992-1993 Collective Agreement was in
effect. This evidenced, in the employer's view, the union's continuing
reliance on that agreement. If, indeed, it was truly the union's position that
the Memorandum of Settlement was superseded by the 1992-1993
Collective Agreement, why would it, counsel asked, continue to rely on the
terms of that agreement in arbitration cases before the Board? Counsel
referred the 8oard to two awards indicating the union's continuing reliance
on the terms of that agreement after the 1992-1993 Collective Agreement
came into effect. The only conclusion that could be drawn, counsel argued,
was that the union understood and intended the Memorandum of Settlement
to have a continuing effect. Moreover, the employer took the position that
it could have argued in these cases that the Memorandum of Settlement had
been surpassed by the 199Z-1993 Collective Agreement, but did not do so
because it too understood that that agreement was to have a continuing
effect.
Counsel referred to the Anderson et al 291/89 (Dissanayake) award. This
case is complicated. However, it appears to have involved a number of
grievors, similarly situated to the grievors cOvered by the Memorandum of
Settlement, who signed their own memorandum of settlement providing for
compensation in return for the withdrawal of their grievances.
Subsequently, these grievors sought to take advantage of the Memorandum
of Settlement, but were instead confronted with their own settlement
which the employer argued permanently disposed of their grievances. This
argument was accepted by the Board which Pointed out that:
Arbitrators have consistently stressed the sound
industrial relations purpose serviced by upholding
grievance settlements as final and determinative
dispositions of disputes...
Quite apart from. the general labour relations policy in
favour of treating grievance settlements as final and
conclusive determinations of disputes, in the minutes of
settlement with regard to the present grievances, the
parties have taken careful and explicit steps to make it
clear that the settlement is final and conclusive. The
union grievance settlement and the settlement of these
individual grievances address both the issue of liability,
i.e. the proper status of the grievors' employment, as
well as the remedy. The memorandum of agreement with
regard to these 3 grievances devotes paragraphs 3 to 5
inclusive, to make it clear that all aspects of the dispute
are at an end. To remove any possible doubt, in paragraph
6 the parties explicitly agree that "the Memorandum of
Agreement constitutes the complete and final agreement
between them". ' (Emphasis added). Paragraph 3 provides
that "Upon signing of this Memorandum of Agreement by
all parties, the grievances shall be deemed to have been
withdrawn." This agreement was signed by the local
union president as well as the grievors (at 8-9).
Having concluded that the matter in issue had been settled, the Board in
Anderson et al dismissed the grievances. ..
Counsel argued that the Anderson et al decision was important in two
respects. First of all, it demonstrated the importance of giving effect to
final settlements reached by the parties. Second, it was noteworthy, in
counsel's submission, that the union was attempting in the Anderson et al
case to have the Memorandum of Settlement apply to those grievors when it
was arguing in the instant case that that settlement had effectively been
trumped by the amendments to Article 25.1 found in the 1992-1993
23 ~
Collective Agreement.
It was interesting, in this respect, that neither the 1991 Grievance nor the
1992 Grievance put the employer on notice that the union would be arguing
that the Memorandum of Settlement was somehow no longer in effect. When
this evidence was combined with the agreed upon fact that the status of
roll-over employees was not discussed in negotiations, nor did it figure in
Mr. Gibbs's mind when he wrote a memorandum clarifying the proper
interpretation of Article 25.1, it was clear, in the employer's view, that the
Memorandum of Settlement remained alive and continued in full force and
effect.
Indeed, in the employer's submission there was nothing on the face of
Article 25.1 that would indicate that that provision was intended to have a
retroactive application on roll-over employees. Counsel noted that this
provision had an "effective" date of February 3, 1992, and there could be no
doubt, in these circumstances, that the provision was intended to be
prospective effect. While Article 25.1(d) did provide for an effective date
of January 1, 1984, counsel argued that this term had to be read in light of
the overall effective date of the provision when it was considered as a
whole.
Counsel also took the position that the 1991 Grievance and 1992 Grievance
were barred as a result of the application of the principle of res judicata.
Put another way, once a matter is settled, it cannot, counsel argued, be
relitigated and, in support of this submission referred to a number of
authorities including Re Stelco Inc. (Hilton Works) and USW 5 L.A.C. (4th)
284 (Haefling). Counsel pointed out that the parties agreed, in their
tvlemorandum of Settlement, on the formula to be used to calculate the
seniority of the roll-over employees. In this regard, counsel noted that
when the parties reach an agreement to settle a grievance, it matters
little, in terms of its enforceability, whether the terms of the settlement
could have, or would have, been the subject or result of bargaining for a
collective agreement: Very simply, there were, in the employer's view,
fundamental labour relations principles at stake, and those principles
dictated,, in the circumstances of the instant case, that the Memorandum of
Settlement be given continuing effect.
There were also, in the employer's view, a number of other reasons in
favour of a finding that the Memorandum of Settlement continued in effect
even though a new Collective Agreement was subsequently signed. Counsel
referred to Re Penticton and District Service and Hospital Employees' Union
16 L.A.C. (2d) 97 (Weiler) wherein the following is stated: "Thus the
current approach of Canadian arbitrators is to start from the presumption
that the agreement as a whole is made retroactive, as the parties have
stated in their duration clause. But specific exceptions may be read into
· this standard retroactive principle, excluding certain terms of the
agreement from the clause, if full retroactivity would lead to quite
impractical and unintended results" (at 102. In Re Penticton, Professor
Weiler also c~tes Re Canadian Canners Ltd. and lAM 4 L.A.C. (2d) 59 (Schiff)
wherein the following observation is made: "When a new collective
agreement supersedes a predecessor agreement, in the absence of
compelling language in the new agreement arbitrators will not read the new
provision as applicable to events occurring before the date of the new
agreement's execution if the effect of the retroactive reading would be
absurd or would unfairly disappoint the reasonable expectations of those
Z5
who had been Subject to the provisions of the predecessor (at 61 ) (emphasis
added).
In the instant case, there was little doubt, in employer counsel's
submission, that retroactively applying Article ?_5.1 to the rollover
employees would undermine their interests; the very interests the union
sought to protect through the negotiation of the Memorandum of Settlement.
Counsel also pointed out that it had been long-established in the
jurisprudence that the clearest language was required to abridge seniority
rights, and in the employer's submission, there was nothing about Article
25.1 that indicated that it should be applied in such a way so as to abridge
the significant seniority interests that were obtained as a result of the
Memorandum of Settlement. Employer counsel took the position that given
the nature of the interests at stake, any findings about retroactivity should
be only be with the greatest of care.
Counsel conceded that the cases Which he had referred to deal with status
acquired under one collective agreement when that agreement was
subsequently changed in negotiations. In this case, the status that was
acquired was under a Memorandum of Settlement. The difference in
instruments did not, in the employer's view, affect the fundamental
principles to be applied. In counsel's submission, memorandums of
settlement continue in force from one collective agreement to the next. If
this were not the case, counsel suggested, parties to a collective
agreement would have to re-sign all of their settlements at the expiry of
one collective agreement and the commencement of the next.
26
In conclusion, Counsel argued that there' was no basis for finding
retroactivity in Article 25.1 of ~the 1992-1993 Collective Agreement.
Counsel pointed out' that it was agreed by the parties that there was no
discussion whatsoever about the Memorandum of Settlement in the
negotiations leading to the 1992-1993 Cellective Agreement, and he
observed that that the Memorandum of Settlement had been entered into
willingly and freely by the parties. There was, accordingly, no basis to find
that Article 25.1 was drafted to overrule or overturn that settlement and to
establish a new method of calculating the seniority of all employees.
Counsel pointed out that, in any case, Article 25.1 of the 1992-1993
Collective Agreement gives an effective date of February 3, 1992, and this
date establishes that the provision was not intended to have a
retrospective effect. Accordingly, counsel asked that both grievances be
dismissed.
Submissions of the Third Parties
Mr. Straszynski began his submissions on behalf of Mr. Reynolds and other
third parties by referring to some of the facts. He noted that Mr. Gibbs
testified that the June 8, 1992 Memorandum was not intended to deal with
the status of roll-over employees, and there was no basis, therefore, for
arguing that it evidenced any intention on the part of anyone to
retroactively apply Article 25.1.
In Mr. Straszynski's view, settlements were inviolate. Settled grievances
were not, he pointed out, arbitrable, and this is why, he argued, the present
grievances were not properly before the Board: the matter in dispute had
already been resolved, and counsel cited Re Stelco (Hilton Works~ and USW,
referred, to earlier in support of the proposition that once an issue is
resolved by a memorandum of settlement that same issue, cannot be
subsequently raised in a new grievance, even where the terms of settlement
deviate from the strict terms or language of the collective agreement.
Counsel noted that the parties had both been represented in the settlement
discussion, and both parties had the expectation, when they signed the
Memorandum of Settlement, that the deal they reached - their full and final
settlement - would be honoured in the future. And, in Mr. Straszynski's
view, the Board routinely declines jurisdiction in cases of this kind and
cited Anderson et al in suppOrt of this submission.
In the alternative, counsel argued that Article ?_5.1 was not applicable to
the roll-over employees. Counsel submitted= that the roll-over employees
had their seniority, on entry into the full-time ranks of the Ontario Public
Service, calculated by the Memorandum of Settlement and not by a term of
any collective agreement, Counsel pointed out that Article 25.1 sets out a
formula for the calculation of the seniority of seasonal employees, not
roll-over employees, and took the position that it was therefore
inapplicable in the instant case. Referring to a number of documents
introduced into evidence, Mr. Straszynski argued that the roll-over
employees were a group separate and apart, and that is why a specific
Memorandum of Settlement was reached providing for the calculation of
their seniority.
With respect to seniority, counsel referred to the Tung Sol case, and
submitted that seniority should only be detrimentally affected by the
clearest provisions. There was nothing in Article 25.1, in Mr. Straszynski's
view, that evidenced any intention of the parties that it should be applied
to the roll-over employees with the result of diminishing their seniority
28
and entitlements. The. reference, in that provision, to seasona~ employees
was, counsel argued, insufficient to encompass ~he ro~-ove~ employees for
they were no ~on~er seasona~ employees.
Mr. Straszynski also took the position that the Memorandum of Settlement
was a collateral contract, and was not, in the circumstances of this case,
superseded by the negotiation of a subsequent collective agreement. There
was no basis in the agreed-upon facts or evidence to find that the
Nlemorandum of Settlement had somehow lapsed, and absent explicit
language to this effect, counsel argued that it should be given continued .
effect. In Mr. Straszynski's view, the parties signed a Memorandum of
Settlement, and the third parties were entitled to continue to rely on it.
Accordingly, he too asked that the grievances be dismissed.
Union Reply
In reply, union counsel argued that the grievances were arbitrable, and
suggested that the Article 25.1 was clearly intended to apply to seasonal
employees who had obtained classified status. Counsel also took the
position that the union was not, in this case, taking issue with the general
proposition that settlements, for good or for ill, must be respected. What
the union was doing, however, was arguing that a settlement can be
overturned or succeeded by the parties in their post-settlement collective
agreements, and that in this case, section 3 of the Memorandum of
Settlement was overtaken by Article 25.1 of the 199Z-1993 Collective
Agreement. The remainder of the settlement remains in force.
Counsel also took the position that there was no case standing for the
proposition that individual employees have an estoppel-like interest which
they can assert in a collective bargaining relationship, and argued that
there was nothing stopping the union and the employer from modifying a
Memorandum of Settlement through the negotiation of a new collective
agreement term. And this, counsel argued, is exactly what had taken place
in the instant case. The whole purpose of Article 2_5.1, counsel submitted,
was to create a level playing field for all employees regardless of how they
joined the classified ranks, and to do so through the application of a
uniform system of seniority calculation.
Counsel noted that the employer issued a memorandum dated June 8, 1992,
and while it was true enough that Mr. Gibbs testified that he' reviewed that
document with a union official, there was no evidence of what exactly they
discussed. Certainly, it was open to the Board to find that that
memorandum was intended to cover all employees including the roll-over
employees, for it did not exclude them from its intended operation.
What possible reasons could there be, counsel asked, for giving roll-over
employees greater seniority than employees who had posted in if both types
of employees had, in fact, exactly the same continuous service? Counsel
suggested that there was no answer to this question. In counsel's
submission, the integrity of settlements was not the issue in this case.
What was in-issue was the language of Article 25.1 of the Collective
Agreem'ent, and counsel argued that that language provided a formula for
the calculation of the seniority of all employees, including those who
rolled-over pursuant to the Memorandum of Settlement. Counsel again noted
that had the 199;?-1993 Collective Agreement provided a richer formula for
the calculation of seniority than the one found in the Memorandum of
Settlement, it would have been most unlikely that the employer would have
30
said claimed that the roll-over employees were barred from the benefit of
the new Collective Agreement. bargain on the basis that they had earlier
agreed to different terms in a Memorandum of Settlement. Counsel
concluded with the observation that the union did not take any pleasure in
seeing the seniority of some of its members reduced. It was responsible,
however, to all of its members. And that is why it negotiated Article 25.1;
to ensure that everyone had their seniority calculated in the same way.
Accordingly, counsel asked that both grievances be upheld and that the
appropriate declaration be issued.
Decision
Having carefully considered the evidence and arguments of the parties, we
have concluded that the two grievances before us must be dismissed.
As noted earlier in this award, the union takes the position that certain
provisions of the 1 992-1993 Collective Agreement retroactively
readjusted the seniority of the roll-over employees by providing a new and
commons basis for the calculation of seniority of all employees. The
employer, and third parties, take the position that the new Collective
Agreement does not supersede the terms of the Memorandum of Settlement
ahd that its results, therefore, should not be interfered with..Put another
way, the Board must, in determining the two grievances before it,
determine if the seniority of the roll-over employees continues to be
calculated by the Memorandum of Settlement, or if it should be calculated
by the provisions of the 1992-1993 Collective Agreement. In our view, and
for the reasons that follow, we have concluded that the Memorandum of
Settlement remains in effect. We have reached this conclusion for a
number of reasons.
31
The Sanctity 'of Settlements
It is absolutely essential that the Board give effect to final settlements
reached between the parties. This principle is well-established in the
Board's jurisprudence. It was given effect in Anderson et al, a case
referred to earlier in this award, and it has been repeated time after time
in a legion of other cases including Landry-King 1593/84 (Knoph) where the
Board held:
The Board wishes to do everything possible to foster and
honour settlements reached by the parties. Once
settlements are achieved, parties must feel confident
that they can rely upon them. Otherwise, there would be
no incentive for the parties to even attempt to settle
matters. Unless there is a compelling reason why a
settlement once obtained, cannot be honoured by the
parties, this Board should not even attempt to interfere
with the Settlement (at 8-9).
In Edgett et al 2476/90 (Dissanayake), the Board held, following an
extensive review of the cases, that:
Those policy considerations supporting the need to
uphold the final and binding nature of grievance
settlements recognized by private arbitrators and the
Ontario Labour Relations Board, apply with equal vigour
and force in proceedings before this Board. The purpose
of-the pre-arbitration grievance procedure under the
collective agreement is to provide the parties an
opportunity to resolve disputes informally, promptly and
without the expense and delay of arbitration. Besides, it
is generally accepted that a settlement reached between
the parties is a far preferable way of resolving a dispute
that an award handed down by a third party. If the
efficacy of a settlement so reached is to be maintained,
the parties must be held to their agreement..(at 10-11).
32
It shou)d be also be noted that the Board does not, in genera), concern itself
with the content of sett)ements. As noted in Vinal) et a) 1270/86 (Gray):
The enforceability of a grievance settlement cannot
depend on whether the terms of the settlement reflect
what an arbitrator would have done or could have done in
response to the original grievance. Nor can it depend on
whether it would have been within an arbitrator's
jurisdiction~ to impose the terms which the parties
incorporated into the settlement. Limiting .the
enforceability of settlements in those ways would
effectively negate one of the considerable attractions of
dispute resolution by negotiated settlement - that the'
parties are not confined, as an arbitrator would be, in
defining either the scope of the problem they wish to
resolve or the nature, of an appropriate response to it.
Similarly, the enforceability of a grievance settlement
cannot depend on whether its terms could or would .have
been the subject of bargaining for a collective
agreement. If settlements are to be encouraged, any
lawful provision of a settlement agreement must be
enforceable, and enforceable in the same forum as any
other such provision (at 14).
In the instant case, a grievance was filed and the parties entered into a
"full and final" settlement with respect to it. This Memorandum of
settlement conferred, as the additional agreed-upon facts demonstrate, a
substantial benefit upon a group of employees. While we may not Ilke the
settlement, or its impact, namely the creation of a two tier' seniority
system, there is no doubt whatsoever that it is neither unlawful nor is it
contrary to public policy. For whatever reasons, the parties decided to
resolve a dispute between them by acceding to its terms - terms which
were then, and which continue, to have effect. The only possible basis for
overturning the Memorandum of Settlement, and its results,, would be by
finding that the parties agreed, in collective bargaining negotiations or
otherwise, to set it aside. And, for the reasons that follow, we find no such
agreement.
The Settlement Continues to Have Effect
Union counsel made a number of arguments in support of the union's
assertion that the parties, in agreeing upon a new Article 25.1 in the
1992-1993 Collective Agreement effectively or constructively addressed
the problem which arose from the implementation of the Memorandum of
Settlement, namely the creation of a two-tier seniority system, by
negotiating a new, and common, basis for the calculation of the seniority of
all employees.
There is no doubt that the union responded .in a timely way when the
implications of the Memorandum of Settlement became clear. On August 6,
1991, a grievance was filed, its purpose, as union counsel observed, was
clear: to remedy the imbalance in seniority' calculation. There is also no
doubt but that the parties, soon after this grievance was filed, entered into
collective bargaining and changes were made to the relevant seniority
provisions of the Collective Agreement. While a grievance was outstanding
at the time of these events, the evidence demonstrates that neither this
grievance, nor the consequences of the implementation of the Memorandum
of gettlemer~t, were discussed in negotiations. Nevertheless, changes were
made to the seniority provisions, and the un!on took the position that these
changes reflect the intention of the parties to deal with the outstanding
issue in dispute. With respect, we disagree.'
In our view, the absence of discussion is not fatal to the union claim.
.Where a union grievance is outstanding and where amendments to the
34
Collective A~reement are s~bsequently made, one can s~rmise that the
events are not unrelated. What matters, however, is the nature of the
change and the language that is used. The new Article 2_5.1 begins with the
words "Effective February 3, 1992_..." The case could probably be decided on
the interpretation of these words alone. These words are prospective, not
retrospective. They indicate that from February 3, 1992_, seniority will be
calculated according to the terms set out in the following text. Moreover,
the roIFover employees already had had their seniority calculated. This
provision applied to new employees,' not to classified employees with
recognized seniority dates.
The fact of the matter is that the interpretation of this provision would
result in lesser seniority for seasonal employees who rolled-over following
the "effe~:tive date," and it may be that this is also unfair. But, that, of
'course, is not the issue before the Board. The matter before us is the.
construction of the provision, and we are of the view that it does not apply
retrospectively. "Effective" means, "starting from," "from now on." Any
doubt about the prospective nature of the term is resolved by examining the
last three lines of the provision which state: "Effective December ZO,
1990, any leaves-of-absence granted under Articles 3.9 and 3.35 shall be
included in the calculation of length of continuous serVice.''. Obviously, a
leave of absence granted prior to December 2_0, 1990 would not be included'
in the calculation of length of continuous serVice (at least not under this
provision).
Given the use of the word "Effective," followed by the assignment of a
particular date, we cannot find the parties intended to the provision to have
a retrospective effect. It is, of course, true enough that Article 25.1(d) is
effective from January 1, 1984, and this is a key provision insofar as the
calculation of seniority for seasonal employees is concerned. However,
Article 25. i(d) cannot be read separately from the introductory words in
the provision. But even if it could, it does not apply to the rollover
employees for they were no longer seasonal employees when this provision
came into effect. They were members of the classified service with
already established seniority dates. Article 25.1(d) only applies to
seasonal employees who join the classified'ranks after February :~, 199;).
it is most unlikely that the parties, in signing the Memorandum of
Agreement, or in negotiating Article 25.1 in the 1992-1993 Collective
Agreement intended to create a two-tiered seniority system. No doubt, had
the parties been aware of the implications of the Memorandum of
Agreement, they would have adjusted its terms. That, however, is not a
reason for us to negate the Memorandum of Settlement or give Article 25.1
a meaning that it cannot reasonably bear.
it is true enough that the union continued to raise concerns with respect to
the consequences of the Memorandum of Settlement - the filing of the 1 992
Grievance is evidence enough of that. However, it is also clear that at this
very same time, the union continued to assert that the Memorandum of
Settlement remained in effect. Any doubt about the parties views on this
point is resolved by referring to the Anderson et al case. In that matter,
postdating the signing of the 1992-1993 Collective Agreement, which,
according to the union retroactively adjusted the seniority of the roll-over
employees, it is quite clear that the parties acknowledge that the
Memorandum of Settlement remains in effect. Obviously, this position is in
direct conflict with the union's position in the instant case. The fact that a
member of management subseqUently wrote a memorandum setting out his
view of the proper interpretation of Article 25.1 is neither here nor there,
particularly since that same person also testified that he had not
considered, in drafting that June 8, 1992 memorandum, the.status or
seniority calculation of the rollover employees.
In further support of its position the union argued that side-bars, or letters
of understanding do not necessarily continue from one collective agreement
to the next. This is undoubtedly correct. However, the Memorandum of
Settlement is different, It is a comprehensive agreement signed by the
parties resolvin9 a serious outstanding matter between them and conferring
significant rights' on approximately One thousand .employees. Those rights
crystallized in the immediate aftermath of the parties' agreement, and the
employees concerned began to 'enjoy, for the most part, new or increased
benefits. The rollover employees had their classified service seniority
calculated after the Memorandum of Agreement was signed, and there is no
reason to find that this seniority date was, or would be, subject to further
revision. What the Memorandum of Settlement provided for was the
determination of a continuous service date. That date will remain in effect
throughout the employment of the' rollover employees unless the parties,
through negotiation, decide otherwise.
As a general matter, and unless there is evidence indicating a contrary
intention, an employee's seniority date does not change from one collective
agreement to the next. No matter how or when obtained, it continues in
force unless there is some compelling reason to find that the parties have
'intended to retroactively adjust it. To retrOactively readjust the seniority
dates of the rollover employees, given the magnitude of such a change on
members of that class, some specific language would be required. Not only
is there no such language in this case, none of the surrounding
circumstances, as revealed in the evidence about collective bargaining
negotiations, not to mention the evidence with respect to the parties'
continuing reliance on the Memorandum of Settlement, assist the union in
the prosecution of its claim.
Even if Article 25.1 were ambiguous, and We find that it is clear and
prospective in intent, there is really only one background fact that assists
the union in this case: the presence of an Outstanding union grievance at
the time of negotiations followed by a change in the seniority text, In the
circumstances of this case, however, when 'all of the factors are
considered, this one background fact is, in our view, simply insufficient to
evidence an intention to institute a significant and far-reaching change -
one with potentially dramatic effects on the benefits enjoyed by an
extremely large group of emplo);ees. Benefits, we must add, which were
conferred upon them by an agreement reached between the parties.
Needless to say, it is completely open to the parties to agree to set aside
the Memorandum of Settlement and .provide for the recalculation of the
seniority dates of the rollover employees in accordance with Article 25.1
and, in that-way, ensure the uniform calculation of seniority throughout the
bargaining unit. That is a choice that they'can make. However, there is no
basis in this case to find that this choice has been made. And in the result,
the Memorandum of Settlement continues in effect, and will do so until the
parties meaningfully indicate a joint intention that it be otherwise.
From Tung Sol 'forward arbitrators have emphasized the importance of
seniority. Seniority provisions must be strictly construed. Significant
seniority rights were obtained by the Memorandum of Settlement, and those
~ights can only, and should only, be truncated, abridged, or forfeited, by
very clear language - language which, as we have found, is completely
absent in this case.
The results of the Memorandum of Settlement may be unpalatable; Some
employees may have received a windfall, while others, given the relative
nature of seniority, have been disadvantaged. But it was, the parties'
decision. If they want to change it, they are free to do so.
In the result, and for the foregoing reasons, both grievances are dismissed.
DATED at Toronto this Z8th day of September 1995.
.,~j"/ .,~./~ ..
__Z_ 'f;
William Kaplan
Vice-Chairman
Fred Collict ~
Member
I dissent. Ebasons to Follow.
Menno Vorster
Member
DISSENT BY UNION NOMINEE
MENNO VOllSTE~
Ontari. o Public Service EmpI0yees Union
\
and
~ o£Natural ResoUrCes
Union Grievance - Seniority
(G.S.B. #1526/9! and 1294/92)
I must resp~ c[~sellt i~om t~e opinion of (lie Inajority irt tJ2Js Award and do so most'
emphatically. I submit that the Conclusions expressed by the Chair will have a decidedly
ctet~mentaI effect on the labour relations between these parties.
The Board concluded ~mt in the last round of bargaining~ the parties purposely intended
to negotiate seniority provisions that perpetuate, and even expand, a multi-tiered seniority
system. In reacl:dng w~t I believe to be an erroneous conclusion, the board has seriously
prejudiced the employment security of hundreds and perhaps thousands of bargain/ng unit
members in favour of the rollover appointees to the classiBed service.
The facts leading to t[gs dispute were laid out iu detail dur/ng the course of the hearing
and have to a large extent been recounted by the Chair. The Employer and the Union had for
years been governed by the same ground rules for the aecum~tion of seniority by al! baxg~ing
unit employees, namely those found in Article 2,5 of the 1989-1991 collective agreement between
.the C-overnment of Ontario and O.P.S.E.U. on June 13, 1991, the parties agreed:to give the
rollover employees a more generous seniority calcula~on formula as part of the "rollover
settlement". Almost irnmecli~tely afterwards, on August 6, 1991, the Union flied the ~[rst of two
grievances in an effort to rectify this untenab]e labour relations situation. Within a f~w months,
however~ the Union believed it had bargained with the employer the most sensible labour
2
reblions solution: the 1992.-93 co]].ecth~ agreement brought in sweeping changes to the m~ner
by which ~ll employees would ]nave sen/ority calculated in the same manner in the future, In
doing so, the parties reverted back to a single semiority formula for ail employees.
In denying the g,zievance, the majority rejects the notion that the parties intended to
return to the single formula seniority system applicable to all employees. Instead, the majority
says that the newarticle P_.5 is "prc~eetive" and not "retrospective", and therefore does not apply
to any employee who tran,,ferred from unclasped status to the classified stagprior to Februm7
3, 1992. In doing so the Board majority has esmbhshecl three dist/net seniority calc~tions for
class/fled full-tt~e employees in the same barga/ning,mit 'Pnere is now effectively one seniority
form, da for pre-February 1992 "bid-in" appointees to the e. lass~ed service; another more
gealerous formula for all post-Felmmry 1992 appointees, andyet a third, gold-plated formula for
rollover employees. So much for the sanctity of seniority vcithin the collective agreement. I
would submit that the parties could not possibly ]nave intended thi.~ result.
T}le uncontradicted evidence before the board was that in June 1992 the Employer had
applied Article 25.1 "retrospectively" to the bid-in employees wtzo were appo/nted prior to
Februm-y 3, 1992. Management Board negotistor Brent Gibbs gave tmrefuted evidence
condusively demonstrated th.t it was the mutual intent of the parties to apply the recalc~,l.tion
of seniority flowing from Article 25.1 to ali ex/sting classified employees in the bargaining ~mit
rather than to restrict its application solely to any future appointments to the classified sta~.
w~uld respectfulbr submit that to thi.~ extent, the majority ruling amends the collective agreement
as it ha.~ been negotiated, signed, and applied by the parties.
I would fm-ther suggest that the uncontradicted evidence demonstrates that the majority
has simply misinterpreted the concepts of "retrospectiv/ty" and "prospectivit~' in the labour
relations context and as it apphes to Article 9,5.1. Properly interpreted, article 9.5.1 is not
"retrospective" in its apphcation in any respect: ail seniority-based rights such as job competitions,
3
job security, vacation, etc., prior, to February 3, 19912, continued to be determined by the
seuiority £ormulas either in the expired*collective agreement or the Memorandum of' Settlement
govern~ug rollover employees. This is precisely how it is interpreted in the' memorandum by
M/nishynegot~, tot Brent Gibbs which was entered into vidence.. The new Article 9,5.1 required
the reca!cttl_~tion on February 3, 1992 o£ the seniority of' ."all employees" with regard to
prospective seniority-based rights in future job competitions, layot~fs, vacations, etc. The proper
interpretation of Article 9,5 is quite clear: on February 3, 1992 all bargaining unit employees,
including "rollovers", have their seniority recalculated on .a new form,Sla: Thh recalculated
seniority applies to future job competitions, layoffs and recalls, vacations and so on, but no.__~t to
any of those entitlements that arose prior to February 3, 1999..
I vmuld respect~ submit ~Hat the majority further m/sinterprets the the Tunf Sol case.
That Case, and those hundreds of arbitral awards tb~t have cited it as authority for the great
importance of employee seniority' based upon length of service, is about the seniority of
emplofees who returned to work after a strike only to find that their employer had credited
seniox/ty for the length of the str/ke lo stzikebreak/ng employees but not to strikers. Judge Reville
was smtck by the unacceptable labour relations consequences of' giving str/kebreaking employees
an,mr'air a~tage over strikers in seniority. He did so because seniority is rfitst and foremost
a relative concept which provides (as the. majority in ~ award says) "a common measuring stick"
for all employees who wish to ma/ntain employment security.
In the collective agreement between these parties, Article 24 provides for employment
security based upon continuous service as determined by Article 25.1. Notice of layoff,
redeployment to vacancies and bumping are ali determined by the relative seniority between
classified employees. The very livelihood of ali employees depends upon relative seniority.
The Union's pc~ition and, I sub_m/t, the correct interpretation of article 9.5.1, does amencl -
the "absolute" seniority rights of the rollover employees which resulted from the "ro].lover
4
settlement": vamtion~ severance anc[ pension entitlements. However arlicle g5 does ~ abridge
the to]lover employees' "relative" seniority rights except to the extent that it eliminates the
wincl[~ anhmn~age enjoyed by rollover employees over similarly situated bid-in employees.
Given the evidence and labour relations common sense, I beheve th~.~ is the only
reasonable interpretation o£article 25.1 in the 1991~-3 collective sgreement. For that reason, I
would have allowed the grievance and remitted the master to the parties £or discussion of'
remedy.
Respectfully submitted,
Meauo Vo~ter
Vice-Chair's Addendum
I have read the union member's dissent, and consider it appropriate to
make a few observations in response. The Board did not "conclude that in
the last round of bargaining,-the parties purposely intended to negotiate
seniority provisions that perpetuate, even expand, a multi-tiered seniority
system," What the majority of the Board did conclude was that the
Memorandum of Settlement remains in effect as the parties did not, in
bargaining, address the anomaly resulting from it, While changes were
made to the relevant seniority provisions of the Collective .Agreement,
having considered all of the evidence, including the outstanding union
grievance, we could not fairly conclude that the new provision was
intended to address the impact of the Memorandum of Settlement, and we .
reached that conclusion following a careful review of all the background
facts as well as the specific language of the provision.
A few additional observations are in order. The dissent suggests that the
Board "has seriously prejudiced, the employment security .of hundreds and
perhaps thousands of bargaining unit members in favour of the rollover
appointees to the classified service." This is simply incorrect. All that '
the Board has done is declare that the Memorandum of Settlement entered
into by the parties remains in effect. It .is noteworthy that the dissent
acknowledges who truly bears responsibility for the situation brought
before the Board: "On June 13, 1991, the parties agreed to give rollover
employees a more generous seniority calculation formula as part of the
'rollover settlement'"(emphasis ours) Exactly. It was the parties who
entered into the agreement, not the Board. All that a majority of this
panel of the Board has done is find that the Memorandum of Settlement
remains in effect. In the same way that seniority is important in labour
relations, so too is upholding agreements reached by the parties.
There is, very simply, nothing in the language of Article 25, nor in the
facts as we have found them, that evidences an intention that the
seniority of all employees be recalculated according to its terms. Had the
parties desired that result, they could have easily said so. While the
dissent makes.a number of observations as to how Article 25 should be
properly applied, it suffices to say, and for the reasons set out in the body
of the award, that the majority finds that this interpretation is not
sustained by the language of the provision.