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HomeMy WebLinkAbout1991-2086.Vandenheuvel et al.94-05-02 '~-...~ "~ .... ,;~'~ i,,i ONTARIO EMP£OY~cS DE LA COURONNE " ,il !" ,; C~OWNEMPLOYEE$ DEL'ONTARiO , : : ""'::"GRIEVANCE C,OMMISSlON DE SETTLEMENT REGLEMENT BOARD DES GRIEFS t$O ~UNOA$ STREET WEST, SUITE 2100, TOF~ONTO, ONTARrQ MSG ~Z8 TELEPHONE/TEL~:PHO~E: (476) 326-1388 1;80, RUE DUNDAS OUEST, BUREAU 2~00. TORONTO ~ONTARIOI., MSG 1Z8 FACSrM~LE/TEL~COP~E ; (4'~6) 326-~'396 2086/91, 2087/91, 2088/91, 2089/91, 2090/91 IN THE MATTER OF AN ARBITRATION Un,er THE CROWN EMPLOYEES COLLEcTIvE BARGAINING HCT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN OPSEU (Vandenheuvel et al) Grievor - an~ - The Crown in Right of Ontario (Ministry of the Environment) ...... Employer BEFORE.: W. Low Vice-Chairperson T. Browes-Bugden Member D. Clark Member POR THE R. Davis GRIEVOR Counsel Koskie & Minsky Barristers & Solicitors FOR THE M. Farson EMPLOYER Counsel Fraser & Beatty Barristers & Solicitors HE~RIN~ April 3, 1992 September 4, 1992 ~' May 7, 1993 June 18, 28, 1993 January 10, 1994 February 1, 1994 DECISION The five Grievors, Errol Butler, Dennis Walker, Michele Vandenheuvel, Christopher Hurt and Albert Peterson are all environmental officers employed in the Sarnia District of the Ministry of the Environment. They grieve that they were paid at the "on call" rate for stand-by service time and seek retroactive compensation. Mr. Butler grieved, on October 7, 1991 and seeks compensation retroactive to March 1990. Mr. Walker grieved on October 9, 1991 and seeks compensation retroactive to an unspecified date. Mrs. Vandenheuvel grieved on October 7, 1991 and seeks compensation retroactive to October 21, 1986. Mr. Hurt grieved on September 23; 1991 and seeks compensation retroactive to .lune 24, 1986. Mr. Peterson grieved on October. 10, 1991 and seeks compensation retroactive 'to September 19, 1989. . The grievances c0/5Eern Articles 15.1 and 16.1 of the Collective Agreement which provide as follows: .. "I5.1 ."Stand-by time" means a period of time that is not a regular · .: working period during which an employee keeps himself available for immediate recall to work." "16.1 "On-call duty" means a period of time that is not a regular working period, overtime period, stand-by period, or call-back period, during which an employee is required to be reasonably available for recall to work." The matter first came on before this panel on April 3, 1992 at which' time a 2 preliminary motion was made by the Employer relating to the retroactivity of the claim'. The preliminary motion was dismissed and we were subsequently advised that the Employer commenced judicial review proceedings in respect of that ruling. The parties were, hoWever, desirous of having the matter heard and determined fully on the merits notwithstanding the commencement of the judicial review proceeding on the preliminary ruling, and this panel heard the evidence on a number of days in 1992, 1993 and 1994. The parties alSo agreed that the evidence ol~ Mr. Christopher Hutt could be applied by the Board to the other grievances provided that the.other Grievors were also called to testify. The backdrop for this grievance is the Emergency Response Program operated by. the Ministry of the Environment. This program, referred to as "ERP", came into existence in 1986. The role of the ERP officer on duty was to respond in' an appropriate fashion to contacts made to him or her by the Spills-Action Centre (referred to as "SAC"). SAC acted as the central exchang6 of environmental spills information. Its role was to' respond to spills notification and other environmental occurrences 24 hours a day,. 365 days a year. The Ministry's Policy Manual titled "Spills Action Centre Operating Procedures" with an effective date of March 10, 1986 sets out a number of appropriate actions for an I~RP officer to take when contacted by SAC: "(a) initiating MOE field response by contacting Region~ Emergency Response staff; (b) contacting other agencies as required, e.g., police, fire department, 3 ambulance, Coast Guard, Canutec, municipalities, U.S. authorities; (c) notifying senior MOE management of serious incidents and coordinating information flow with the communications Branch; (d)' establishing contact with the Minister regarding major spills and conveying orders from the Minister where necessary; (e) ensuring that potentially affected parties are notified/warned; (0 liaising with and providing support for agencies in charge when a spill involves an emergency situation; (g) providing information on chemicals and clean-up techniques to MOE staff and others; and (h) recording details of complaints and/or incidents and forwarding them to relevant District Offices or other agencies for response during normal business hours." When the compensation scheme was being discussed in 1986 for ERP staff, the Ministry's operations division p~pared a discussion paper in which the midnight to 8:15 a.m. period was proposed to be designated as an "on-call" period ,for the ERP officer on duty. The paper stated: "Statistics kept since the start-up of the Spills Action Centre highlight~ that very, few call-outs have occurred between the hours of 12:00 a,m. to 8:00 a,m. It would not be appropriate to maintain a high cost "standby" service level for a time period when few calls are likely to occur. The use of on-call for this time period would mean however, that response times would be considerably slower for those few events that do occur." It also stated among its conclusions that: 4 " Since travel time will limit total response time, during "Stand-by" periods ~response staff should depart to the scene within 5 minutes of being. dispatched by SAC. .. For "On-call" periods staff should be given sufficient time to properly awaken themselves and prepare .for departure." On September 19, 1986, a memo was issued by D.p. Caplice, the Assistant Deputy Minister of the Operation.~ Division to all Regional Directors regarding "Compensation. Guidelines to ERP's". The fo!lowing is set out in the memo in relation to telephone calls during stand-by time and on-call time: 'Telephone calIs during Standby time and On-call periods would be considered. as overtime and would be compensated on a minimum basis of 1/2 hour at 1-i/2 times the hourly rate.. A call from SAC to the ERP instructing an assigned employee to report and investigate an emergency situation would be considered as a scheduled recall to work and the first occasion of such recall to work would be compensated on a minimt~m basis of-4,hours overtime at 1-1/2 times the hourly rate (Article 13, Collective Bargaining Agreement) except when the emergency, recall occurs within four hours of the normal work schedule." It was-the evidence of Mr. Hutt that at the inception of the program, a member of management presented the con~pensation package and explained the difference in the rates of pay as between on-call and stand-by periods saying that the midnight to 8:15 a.m. period was being designaied as "on-call" because the chances were that the ERP officer would be at home and thus easily contacted. The balance of the time, the stand-by period, the ERP officer was to carry a pager. On November 25, 1986, Kal Haniff, the engineer and an industrial officer in the abatement section, issued the following memo to the Sarnia office ERP staff re. "On-Call": "In future, when on call, please keep the beeper on 24 hours a day and have the beeper available with you at all times. The procedure that SAC will use will attempt to contact the E,R.P. via pager first, and if that fails/ then will. try other means. It is felt that the contact, via pager will help expedite calls as on some .occasions SAC has tried to contact E.R.P, via home telephone number on off hours and the line has been busy for. extended periods. If there are any questions on this please contact me." The Sarnia district was particularly sensitive environmentally' and was known colloquially as "Chemical Valley'. There was a high industrial concentration in the area and because of the location on the St. Clair River as Well as the area's proximity to the United States, spills to the river had not only potential for great environmental harm, they had an international component as well. A large number of "non-standard procedures" were implemented for a variety of environmental circumstances or occurrences in the Sarnia district. Where an occurrence fell within the ambit of a non-standard procedure, SAC was to notify the ERP officer for action. All spills to the St. Clair River were put into the non-standard procedure category and were treated with due promptness and gravity. In a submission 'to the' Division Head meeting i'egarding, inter alia} the Ministry 'of the Environment's response to spills to the St. Clair River, M. Looby'and J. Luyt of the Southwest Region's Operations Division~ wrote on October 18, 1989: " Special instructions have been given to SAC whereby a!.[ spills to the St. Clair River require an Emergency Response Person (ERP) call-out. 6 The District Environmental Officer (office h°urs) or the ERP (outside office hours) immediately investigates these spills.". On September 6, 1991, in the context of an anticipated revision to the ERP, Gordon Van Fleet wrote to the Divisional Directors, G.W. Scott and R.M. clark, as follows: "In mid August, the proposal was discussed wlth each District Office and there was sufficient staff support for it to be viable at all Iocat/ons except Sam/a,. where all eleven staff objected on the basis that it would result in an unsatisfactory reduction in the level of service, On August 29th~ the proposal Was discussed in teleconference with the Assistant Directors and Abatement Managers,. resulting in some minor fine tuning. Sarnia remains a concern of the Southwestern Region primarily because of sensitivity to spills to the St. Clair River and the perceived need for staff to be immediately available all weekend." The.Employer kept statistics for the average number of minutes that it took ERP officers to attend at a spill site both during stand-by and on-call times for the period January 1, 1988 to September 30, 1991. The average for Sarnia was 34.7 minutes for stand-by periods and 48.4 minutes for on-call period~-j~about a 14 minute difference. This data related only to attendances where an arrival time was recorded and only in relation to spills. No information, however, was kept as to the relative times taken to respond to a SAC contact with other types of appropriate action as set out above, and the data does not include attendances for matters · other than spills. The oral evidence which was adduced chiefly through Mr. Hutt and confirmed and in some cases expanded upon by the other Grievors, disclosed that the ERP staff were all of the understanding that once they were contacted by SAC, whether, during a stand-by period 7 or an on-call period, they were expected to launch into action. Their evidence was to the effect that they did so without delay both because they felt it their professional' duty to do so and because such a degree of promptitude was expected of them by management. They understood that SAC contact, particularly in relation to spills, required immediate response and immediate response was what they delivered. Not every contact, however, warranted a personal attendance at the site, and it was the Grievors' uncontroverted evidence that it was a matter of professional judgment left to the ERP officer as to which action he or she would take in the circumstances. A response might take the form of an immediate personal attendance but it might take' the form of no more than a telephone conversation with a SAC officer and a notation for further action at a later time. Action might consist of other communications as contemplated in the Ministry's policy manual. The evidence disclosed that ERP officers claimed and were paid for the initial telephone call, i.'e. the SAC contact, whether on call or on stand-by. It was claimed and paid as one-half hour of overtime. Where it was necessary to go out,. the'site attendance was claimed and paid as four hours. The Griev0rs testified that it was' understood by ERp officers that if SAC gave an instruction to go out and attend at a site, the ERP officer was expected, to attend at once. Likewise for spills and odours, because of the nature of the incident, the evidence may be gatherable only while the event is taking place and it is necessary to attend at once. It was the understanding that spills were a priority and that it was necessary to attend.immediately. 8 The evidence also disclosed that ERP officers were expected to carry pagers both for' on-call and stand-by periods. More recently, ERP's were provided with portable cellular telephones, thus £acilitating instantaneous communication with SAC without the interposition of and delay created by a pager. It was acknowledged by the Gri6vors that where a site visit was in,~;olved, the time taken to. get to the site would be slower during the midnight to 8:15: a.m. period because gene~'ally the ERP officer would be asleep. It was the understanding of the Grievors, however, that once contacted by SAC, they were expected to act immediately whether it be by way of a telephone communication or site attendance, They did not differentiate between stand-by or call periods in terms of the swiftn~'ss with which they set to work and believed that the Employer expected there to be no difference. Mr. Gordon Van Fleet, the Assistant Director and Abatement Management for the Northwest Region (Thunder Bay), was called on behalf of the Employer. He was involved in the review that led to the changes in the ERP compensation scheme. While his evidence set these grievances in context by highlighting the Employer's motives of minimizing the cost to the public of maintaining the program, he was not able to throw any light on the issue before us, namely the instructions to and 'the requirements and expectations of the ERP staff in Samia. Mr. Van Fleet had never worked in that district. 9 The Employer also called the evidence of Gary Zikovitz, the head of SAC. Mr. Zikovitz testified that where incidents are reported to SAC, the SAC officer relies on three guidelineS: 1. Operating procedure cards which detail what to do and when to call out the ERP officer. These are used for all occurrences. 2. When a non-standard procedure has been put in place (and these are initiated by the district), to call an ERP .officer for action. 3. To exercise a discretion allowed to each SAC officer, justifying the manner of the exercise of the discretion. If there is a serious spill, whethei' with or without a non-standard procedure in place,' the SAC standard procedure requires that the ERP officer be sent out: Mr. Zikovitz further testified in relation to the stand-by/on-call distinction that if an occur[.ence was called in to SAC during a stand-by period, the SAC officer is not to hesitate to call the ERP officer. If the occurrence is reported during an on-call period, the SAC officer is to call the ERP officer only-if really necessary. In our view, the proper inference to be drawn from this is that a call was expected to elicit an immediate disruption of the ERP officer's activities. .In 1991, the Employer had determined to cut its costs by revising the ERP, increasing the on-call to stand-by time' ratio, thus reducing the cost to the Ministry and consequentially the income of ERP officers in the program. At this point, the Grievors ~who had 10 hitherto been content With their overall compensation and who had thus never raised an issue about the differential, in pay as between on-carl and stand-by periods, started to rd'se queries about the difference, if any, in' the Employer's expectations of them during the two different periods.. Early in 1991, the ERP staff at Sarnia commented by memo on the Employer's proposal to implement shift work for the program. Among their comments were the following: "1) Currently we have a program' that works! The public is happy with our responses and we have never had a complaint against the system in Sarnia. Moral is high in Sarnia with the current program.' We respond after midnight as if we are on "stand-by" instead of just "on-call". Dedication is high. In 1989 22% of our call-outs were after midnight. If the compensation/work hours change drastically as proposed there is a possibility that response mechanisms will change as well. 4) We need a definition for "on-call" vs. "stand-by''. With sensitivity high in the Sarnia area we feel that the ERP's are on "stand-by" continuously." On August 9, 199t-, they sent a memo...to D.A. McTavish, Director of the Southwest Region: .. "Sarnia District E.R.P. will not volunteer for the proposed reduced emergency response program. We feel it would be irresponsible for us to volunteer for a program which will' provide reduced ~'esponse to spills in the Chemical Valley. The Chemical Valley industries operate 24 hours a day, 365 days a year and spills to the water and air occur at anytime of the day or night. Also,~the nearest downstream water users are in the order of one hour away. Sarnia E.R.P. have been providing immediate response to spills during· all working and non-working hours. We would appreciate a reply indicating whether or not continued immediate '11 res?or, se is required fo.,' spills in the Chemical Valley." On September 13, 1991, they wrote another memo and put the queStion again: "...in light of the reduced Emergency Response Program starting on' October 1, 1991, we have obtained a working understanding for the. "On-Call" definition under Article 16 of the Collective Agreement. It is the Union's position that one. does not need to carry a pager during "On-Call" periods, therefore it is our intention to turn off the ERP beeper during "On-Call" hours and be "reasonably available". You have not answered our August 9, 1991 letter and we will ask again, do you require immediate response to spills in the Chemical Valley?. Please respond immediately as well as letting us know if you have any concerns with .our interpretation of the "On-Call" definition." On September I9, 1991, a meeting was held, attended by Mr..McTavish and the ERP staff at Sarnia at which the issue of the on-call/stand-by distinction was discussed. On September 24, 1991, Mr. McTavish' sent a memo to the ERP staff containing the following: "Management will continue to accept that there is a difference in response time for staff to be on-site between on-call and stand-by. Management does not expect an immediate response by an individual when he/she is on-call. Only when an immediate response is required and pre-authorized by management will there be an expectation to respond to a call immediately. When on-call you should be able .to be contacted easily. Beepers and cellular phones have made it convenient for this to occur whether you are fishing or at a ball game. Most such contacts, when you actually talk to .SAC should take no longer than one-half hour and with a cellular phone would really not require any time. For.example, when wearing a beeper, if it goes off and you are fishing you do not have to immediately respond to the beeper. It obviously will take you some time to get to a phone. 12 Therefore, when wearing a beeper 'you are not expected to be immediately available to receive a call and would be expected to respond in a reasonable time frame. Only when you have received authorized instructions to be immediately available would it be necessary for you to respond immediately. When contact has been made with SAC the time it will take for you to attend at the site can be determined and if it is an urgent situation 'it may be necessary for SAC to call management to see if arrangements for someone else to attend at the site can be made. This action could be necessary if your earliest time of arrivaI. would 'be longer than 1 to 2 hours from the time of'your contact with SAC." Mr. Hutt had grieved the day prior to Mr. McTavish's memo and the balance of the Grievors grieved shortly thereafter. That the Grievors were highly professional and dedicated and that they brought to their duties a commendable degree of. personal responsibility is beyond dispute. This is to the Grievors' credit and no doubt also to the credit of management'in h/tying pulled together and motivated a team which obviously enjoyed their work and which was rightly proud of the work they were doing. That the work was important to the public 'is also not in dispute. Nor is it suggested that there was anything untoward in the Employer's motive of redesigning the program to reduce its cost to the public. The sole issues are: 1. Whether or not, for a period of time, the Employer expected and required of the Grievors, and the Grievors deliv, ered, a stand-by level of availability but were paid only at the on-call level, and : 2. If so, is there justification for departing from the provision in the 13 Collective Agreement that precludes recovery of'compensation for a period pre-dating 20 days before the gdevance? In our view, the necessary questions to be asked and answered to determine the issue include: 1. What does the ERP officers' work consist of?. 2. When does the ERP officers' work commence? 3. Where does the ERP officer work? The time it is expected to take for an ERP officer to get to a site when a personal attendance is required is a factor to be considered but cannot properly be treated as the sole factor in determining whether the Employer in fact expects and requires a stand-by level of service during .on-call periods. The uncontradictetl evidence of the Grievors was that the nature of the ERP officer's job required the exercise of judgment and the application of knowledge. Indeed, when a contact was made to an ERP officer by SAC, the ERP officer was expected to take appropriate action, which might entail an attendance but equally .might not. part of the job was to take in the relevant and available information from SAC, to assess it, to decic/e on a course of action and to take it. This. function began immediately upon making contact with SAC or upon SAC making contact with the ERP officer. That the carrying out of this function was "work" was recognized by both the Grievors and by the Employer in that the Grievors were paid for performing this function whether or not a personal attendance at a site was involved. It is also apparent from the evidence that the ERP officers' place of work, while it might be his or her usual office for most-other purposes, was, for purposes of carrying out the ERP officers' functions, wherever he or she happened to be at the time contact &'as made with SAC and ensuing communications took place and the site and' the route thereto if a site visit was necessary. Clearly, if a spill notification came during office hours, the grievors, qua abatement officers might go to the site. It could not be suggested that upon leaving the office to go to the site, the officer had left work. Work for these employees included being on the road and getting to occurrence sites. There is no logical distinction between the work done during normal office hours, which included exercising judgment, applying knowledge, making phone calls and travelling to and attending at sites, and the same activities done outside normal office hours. In our view, once the ERP officer has commenced to carry out one or more of these functions, work has begun and we hold that-work commences in a smd-by or on-call period when the SAC contact is made and the ERP officer starts to take appropriate action in relation to the occurrence which has presented itself. ' We were referred to the deciSiOn of Vice-Chairman Tacon in Delaquis, 1599/92, which dealt with a call-back. In that case, the grievor, an ERP officer, alleged that dealing with a spill matter, by telephone constituted a call-back to work. The Board agreed with that con ten tion: "In the instant case, there is no dispute that the grievor performed "work" in 15 handling the SAC call over the telephone. Nor is there any suggestion that the 'manner of responding to the call was inappropriate; indeed, the employer clearly expects that ERP Officers will resolve some matters without attendance at a spill site, at least outside of the normal hours at work. What is vigorously disputed is the proper basis for calculating the compensation payable for the time spent by the grievor on the telephone on May 13. The issue is whether the handling of the SAC. call by telephone is sufficient to 'trigger the call back provision in article 14 or whether the ERP' Officer must actually attend at the spill site or the Minister office to be entitled to call back pay. ~., The Board does not regard the phrase "called back to work" as requiring a ~! physical return to the Ministry office or the spill, site. In the Board's view, the :'~ language indicates that the employee is, no longer free to carry on with his/her . private life but must perform "work" for the employer. For that disruption and inconvenience, the employee is entitled to call back pay. In many instances, the .~, performance of "work" will necessitate a return to the employer's premises. In · the instant case, it is recognized that the ERP Officer is "worldng" when he/she ~';~ handles a SAC call by telephone." We come to the same conclusion, namely that the commencement of work in the context of the ERP;s functions, do~s not necessarily require a personal attendance at an occurrence site. What then is the nature of the Employer's requirement and expectation of the Grievors? In our view, it was the Employer's requirement and expectation that the ERP officer be, for all practica! purposes, equally available to perform work whether on a stand-by period or on an on-call period. The Employer's own communications to the ERP staff are the best evidence of this. No evidence was led to contradict Mr. Hutt's testimony that at the inception 16 of the program, the 'Employer had let it be known that the midnight to 8:15 a.m. time period was being designated on-call because it would be easy to reach the ERP officer who would normally be expected to be at home and asleep. Mr. Hutt's testimony was straightforwar(/an(/ credible and we accept it. In November of 1986, Mr. Haniff directed that pagers be carried on on-call periods, thus eliminating the difference, if any, between accessibility of the ERP officdr while on-call as opposed to his accessibility while on stand-by. It is clear from all of the communications from the Employer on the subject that the focus of its attention was accessibility to the ERP officer. The Employer. wanted to be able to reach the ERP officer instantaneously if possible, even during on-call periods, and the sole purpose in doing so must have been to engage the ERP officer's mind with the occurrence on as close to an immediate basis as' possible. Had the Employer not desired immediate accessibility, and thus an immediate setting ' to work on the part of the ERP officer as contemplated by the Ministry's policy manual, it is tlifficult to imagine why it would-require that ERP officers carry beepers and later portable cellular telephones while on-call. The sole reason for doing so is to effect immediate availability for work as is contemplated by the requirements of this particular job. One might easily contrast the requirement to carry a pager with a requirement that one call in every few hours or leave a telephone number where one might be found. Mr. McTavish's memo of September 24, 1991 is tellingly unresponsive to the qttest/on which the Grievors posed in relation to the requirement that pagers be worn while on call. He does no~ withdraw Mr. Haniff's order of 1986 that pagers be worn. He states that 17 while on~call "you should be able to be contacted easily .... with a cellular phone [it] would really not require any time". The suggestion in the memo that ~'.only when you have received authorized instructions .to be immediately available would it.be necessary for you to respond immediately" seems to indicate that management was then taking the. view that the 'level of availability required of the ERP 6fficer could be prescribed by management at the time of an occurrence contact. This, with respect, is to put the cart before the horse, The length of time it might take to get to a site will turn.-on the locatioa of the site, the road conditions and the location of the ERP officer at the time of the occurrence. None of these is relevant to the point in time when the ERP officer is expected to be accessible and available to start t° deal with the matter about which he has been called.' We do not find Mr. McTavish's memo of September 24, 1991 to be successful in distinguishing the requirements-and expectations of the ERP officer while on-call as opposed to what is expected during stand-by periods. To the contrary, it underlines the requirement of immediate accessibility whether by pager or telephone. The Employer has referred us to and places considerable reliance on the decision of Vice-Chairman Slone in Mongrain, 9099/86, a decision issued in/une of 1988, The issue in that case was whether or not the instructions during the on-call period actually required something greater of the employees tha~ a reasonable level of availability for return to work. · The Mongrain case is easily distinguishable from the circumstances before this panel in that in Mongrain there was very little in the way of a factual matrix present and in particular, management had given no direction to the grievors as to what was expected of them during 0n- call periods. This is in contrast to the case before us 'where management has made it clear that it requires ERP staff to wear a pager orcarry a cellular telephone while on-call. It may also be the case that because of the relative antiquity of the M0ngrain decision, pagers and ~:ertainly cellular telephones had not yet become commonplace applicances as they had by the time of the grievances before us. Thirdly, the question of when "work" recommenced was not considered in the Mongrain case and presumably was not an issue put before that panel. Accordingly, although we do not disagree with the Mongraio decision in principle, it is so distinguishable on its facts that it is not of assistance in deciding the issue on the facts before us. The Employer has also referred us to the Samieson decision, 162/77, a decision of Vice-Chairman Prichard, and we agree with the comment in that case that "...each case of this kind .will require a judgment based on a consideration-of all the relevant circumstances and in recognition of the fact that the parties' have created the two separate statuses. The particular arrangements will vary from work place to work place and a decision in one setting may not be readily transferrable to another". Likewise, in' the decision· of Walker and Taylor, 417/82, Vice-Chairman Samuels remarked: "Firstly, the matter is not decided simply on the language which the employer uses. Merely calling the pager system "on-call" does not make an Article i6 situation. The question .is, what are'the real requirements of the duty? Secondly, one gets at these real requirements by examining the circumstances of the job, and the written and verbal instructions to the emplOyees.". The facts in that decision concern the manning of the OPP command trailer which was used in emergency circumstances. The gfievors were placed on an' on-call rotation but the very nature of the work involved, namely the manning of the OPP command trailer in 'emergency or disaster s!mations, required immediate response both to the pager call and to the Order to bring the trailer. No other conclusion would make any sense in the circumstances, and the grievances were alloWed. The parties have referred us to a number of other cases which have dealt with claims for stand-by pay during a period designated by the employer' as on-call. If a common thread can be found running thr~ough the cases, it is that one must look at the nature of the work, including when and where it is done, the instructions given by management and the expectation by management of the employees. Considering these factors, we are of the view that there was no distinction between What wa~ expected and required of these Grievors during on-call periods frOm what was expected and required of them during stand-by periods for purposes of the application of the Collective Agreement. This leads us to the Second question, which is whether or not the normal "20 day rule" should apply. It was Mr. Hutt's evidence that the Grievors simply carried on ~upplying one level of readiness for action throughout without seriously putting their minds to whether there was any distinction or not because they were happy with their compensation and it was not until the compensation scheme was threatened that they raised' their voices in protest. It is well established jurisprUdence in this Board that what is required to start the clock running is a subjective knowledge on the part of the Grievor that he has cause for complaint. We heard no evidence from any of the Grievors that they were subjectively ignorant of the fact that they had cause for complaint until the date of their grievances or up to 20 days prior to those dates. Indeed, the rationale for not having grieved earlier was n"°t that the Grievors did not know that they had a grievance but rather that they were overall content with their situation. On the preliminary motion brought by the Employer, we held that we could not make a.finding that the Grievors were estopped from claiming retroactive compensation for' the period prior to 20 days' before the date of the grievance since, based on the evidence adduced for the.purposes.of the preliminary motion, we could not conclude on a balance of probabilities that the Collective Agreement had been violated at all. We have now heard all of the eviden'ce a/~d are of the view that there is no material before us upon which we can draw the inference that the Grievors lacked, for up to Six years in certain cases, subjective knowledge of the existence of a complaint or difference. Accordingly, we are of the view that. the provisions of Article 27.2.1. should apply, and that retroactivity in compensation shall extend only to 20 days prior to the date of each of the grievances filed. The Union has sought declaratory relief and ia the hopes that it may be of use and guidance to the parties in calculating the proper compensation and in governing their future conduct, I make the finding that until the Employer withdraws ihe requirement to carry pagers or cellular 'telephoneS, it is expecting and requiring a stand-by level of readiness and ought to be paying its employees for such level of service in accordance with the Collective Agreement. It ~,s hoped that the parties will work out the appropriate compensation therefor~~ a it would be most regrettable if after the extensive evidence, the ma~ter had to come on once again before this Board. Should the parties be 'unable to agree between themselves as to the 21 quantum of the compensation, the panel wilt remain Seized to quantify the award. There shall be interest on any sums calculated to be payable. DATED this 2nd day of 1/ay , 1994. W. -Chairperson T. B!&EN, Member "I Partially Dissent" (see attached) D. CLARK , 14ember PART ~ AL DISSENT GSB #2086/91, ETC. OPSEU (Vandenheuve! e~ al) and The Crown in Right of Ontario (Ministry o£ the Environment) I agree with the decision that retroactivity in compensation should be limited to 20 days prior to the filing of the grievances. However, with re,peet, I do. not share the view of the majority that the Employer expected or required stand-by level of response during on-call period~. In the discussion paper of April 25, 1986 (Exhibit #4§) it stated at page 3: "Statistics kept since the start-up of the Action Centre highlight that very few call-outs have occurred between the hours of 12:00 a.m. to 8:00 a.m. It would not be appropriate to m~intain a high cost "standby" service level for a time period when few calls are likely to occur. The use of on-call for this time period would mean however, that response times would be considerably slower for those 'few events that do ·occur". (emphasis added) The Employer, therefore recognized that response times would be slower. In addition, Mr. McTavish's memo to the E.R.P.' Staff of September 24, 1991 (Exhibit #1Z), stated "... Management does not expect an immediate response by an individua.1 when he/she is on-cai1 0..". In my opinion, the Sarnia District E.R.P. officers responded to the events as 'quickly as they did more out of a sense of. dedication and professionalism than an understanding that management expected them to respond immediately. I fully agree that, as w~s indicated in the award, the grievors were highly professional and dedicated employees and that they brought to their duties a Commendable degree of personal responsibility. The issue, however, is whether the Employer expected and required of the grievors a stand-by level of availability when on-call. with respeet~ in my opinion, the EmD10yer did not and the grievors were appropriately compensated. Do~'M. Clark, Member