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BOARD DES GRIEFS
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1929/91
IN THE NATTER OF AN~RBITR~TION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEV~%NCE SETTLEMENT BOARD
BETWEEN .
O?SEU (Union Grievance)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of Correctional Services)
Employer
BEFORE= A. Barrett Vice-Chairperson
W. Rannachan Member
D. Montrose Member
FOR THE A. Ryder
GRIEVOR Counsel
Ryder, Whitaker, Wright
Barristers & Solicitors
FOR THE J. Benedict
EMPLOYER Manager, Staff Relations & Compensation
Ministry of Correctional Services
HEARING May 14, 1992 May 14, 1993
May 4, 1994
DECISION
This grievance is worded in the following form:
"STATEMENT OF GRIEVANCE
The Union grieves that management at the Chatham Jail is
in violation of Article 18 of the collective agreement,
eliminating certain ~Post' position(s) at the jail.
SETTLEMENT DESIRED
That management cease and desist these procedures by re-
establishing those post positions.
DATE August 15, 1991"
The Chatham Jail~ is a small maximum-security institution
hou'sing about 50 inmates. Correctional Officers are assigned to
"post" positions in various parts of the jail, which is a rambling
five-level structure built in 1849. Just prior to.the grievance
being filed, management reduced the number of post positions on the
day shift from five to four, and the night shift from three to two.
Shortly after the grievance was filed, the fifth post position on
days was reinstated, and a third post position was added to the
night shift. These numbers are all minimum numbers, and the
complement would be increased from time to time to accommodate
special situations, Such as a suicide watch, escort duty or a large
number of fresh admissions. The union says that the minimum numbers
are simply not adequate to properly guard the inmates and thus
protect the health and safety of the correctional staff.
The union identified three areas of concern where lack of
staff meant security precautions were not being properly carried
out and standing orders were violated.
The first area of concern is perimeter patrols. The Ministry
Policies and Procedures Manual requires that staff do "routine
perimeter patrols". The practice at this institution .is to patrol
once a day around 5~00 p.m., and it takes about five to ten minutes
to. complete. Correctional Officers testified that the officer in
charge of that duty might miss it four to Six times a month because
he is too busy doing other things. The purpose of a perimeter, check
is to ensure that nobody is passing contraband in or out of the
jail or attempting to set up an escape. Dangerous contraband
consists of weapons or drugs, both of which are security risks.
The second area of concern is entering occupied areas.
Whenever an officer enters an.area occupied by inmates, he is to
be let in by another officer who holds the key and remains outside
the grill door, keeping the inside officer under constant
observation. Union witnesses say that occasionally the outside
officer might be called away to assist elsewhere and leave the
inside officer alone. This is contrary to standing orders, and in
fact it is a disciplinable offence to leave another officer alone
in those circumstances. Union witnesses say that this has occurred
from time to time, but they have never reported it to management,
and management claims to be unaware of it.
With respect to searches, the standing orders require that two
employees be present during a strip search: one to do the search
and one to observe the officer performing the search. A two-fold
problem is said to emerge here. Sometimes no one is available to
be the observer and an officer will strip search alone. Conversely,
if an officer is called away from another area to assist with the
search then his post position is left unattended for up to five
minutes. This gives the inmates an opportunity to start fights or
pass or use any contraband they may have. Also, says the union, the
lack of personnel means that searches of occupied areas are not
carried out often enough, thus giving the inmates an opportunity
to "stockpile" contraband. On the evidence, there were 114 searches
carried out in 1991 and 159 in 1992. During that two-year period,
contraband was found on five occasions. For some unknown reason
only two searches were carried out in November, ~ 1991, and a
significant amount of contraband was found in one area. That low
search frequency has not been repeated before or since. Standing
orders require that searches of living areas be frequent, thorough
and done on an irregular basis.
Union witnesses described incidents where, in their opinion,
under-staffing led to security concerns. In November, 1991, a fight
broke out amongst inmates in the exercise yard, and the main floo~
and upstairs officers came out to assist, thus leaving their post
positions vacant, for five to ten minutes. In another incident, an
inmate attempted to hang himself, and the upstairs post position
was left unattended while that officer assisted in taking the
inmate~downstairs to the ambulance. Mr. Kostis testified that on
one occasion in December, 1991, he and another officer were
searching an inmate living area when the third officer outside the
grill was called away. The inside officers had.to radio him to get
him tO return. This incident was not reported to management.
A management Security Officer, Mr. John McLagan, raised
security concerns with the Superintendent, Mr. Beaton, in November,
1991. Many of his concerns have now been dealt with and corrected.
The jail is presently undergoing an extensive renovation, and most
of Mr. McLagan's concerns dealt with the physical facilities. He
also raised the concer~, however, that "the staff on duty are
insufficient in complement to properly search inmates and living
areas and the cleaning of them, as this is time consuming for
several staff at any one time, then these duties will be done more
infrequently, letting inmates develop more contraband".
In June, 1992, a "post audit" was completed by a management
Shift Supervisor and an experienced Correctional Officer. The
auditors identified the concern that when one officer was backing
up another officer outside his area, that left his area unattended.
They recommended that both the day and night shift be increased by
one officer each shift, to bring the total posts from eight'up to
ten. When the Superintendent received this audit, he forwarded it
along to Regional Office, which makes the staffing level decisions,
along with a request for funds to hire additional staff. He was
told in no uncertain terms that no funding ~was available for
5
additional staff.
A second audit -has been carried out recently by a
Superintendent from another institution ~ho is auditing all the
jails in the Province, but his recommendations have yet to be
released.
Mr. Beaton testified that when this~ grievance was filed the
jail capacity was 62. It is now 50, with ~ne extra bed to be added
after renovations are finally complgte. He said that if
Correctional Officers are searching inmates or cell areas alone he
would exP~eCt to receive a full written report about it so he could
assure it would not happen again. He is not unduly concerned that
officers leave their posts to assist at;other.posts from-time to
time. He said that the inmates are not supposed to be under
constant visual surveillance: the Correctional Officers have other
duties to perform that take them away from their posts for periods
of time.
The union argues that where both management and union
representatives agree that current staff.ing levels lead to security
concerns ipso facto it follows that the employer has not taken
reasonable precautions for the health ~nd safety of correctional
.staff. While acknowledging that it is an exclusive management right
to set staffing levels pursuant to the Crown EmDloyees Collective
Bargaininq Act, the union argues that management's prerogative is
circumscribed by its requirement to make reasonable provisions for
the. health and safety of staff. The post audit performed fin 1992
by a management-labour team of two recommended.the addition of one
post position to each of the.day and night shifts. Counsel notes
that. Mr. Beaton did not reject this ,suggestion, but implicitly
approved it by forwarding it to Regional Office with a request for
funds. The denial of increased funds by Regional Office based on
financial constraints was not a negative response to the request
on its merits but simply a financial decision made without regard
to health and safety concerns. Furthermore, argues counsel,
standing orders are designed to avoid risk. If they are breached,
it proves that reasonable standards are not being maintained.
Employer counsel responds that you cannot convert what is
essentially a workload complaint into a health and safety grievance
without specific objective'evidence that staffing levels directly
impinge upon the health and safety of staff. Counsel argues that
in all of the evidence we heard there was no nexus established
between perceived risks and the actual health and safety of
correctional staff. The union says there are insufficient searches
of cell areas, but how many are sufficient? And if the frequency
of searches is posing a risk, to whom~ is it a risk? There was no
evidence that when an officer leaves his post to assist another
officer at another post he is leaving behind hi~'a risk to the
health and safety of officers. There is no requirement that inmates
be under 24-hour constant surveillance, and there is no evidence
that links leaving a post to increasing risk to health and safety
of officers. Strip searches should not be done alone but if they
7
are and are not reported, manaqement can hardly be expected to
remedy the problem. Furthermore, if officers have been doing the
searches alone there is no evidence that the practice has affected
their health and safety. The simple fact that certain procedures
are not performed is not, without more, proof of a risk to health
and safety. Counsel posits that while it might be nice for both
management and bargaining unit members alike to have more staff at
the jail, this Board has no jurisdiction to order it without clear
evidence of an existing or clearly potential risk of harm.
We were referred by both counsel to numerous Grievance
Settlement Board decisions all arising out of this Ministry dealing
with health and safety issues. In Haynes, GSB ~1246/89 (Kirkwood),
the Board said, at page 8: "...our jurisdiction is not to enforce
the regulations, but 'to ensure that the terms of the collective
agreement are not violated. Therefore the grievor has the onus to
prove not only the breach of the regulation, but also that the
breach also affected her health and safety." Dowhey, GSB #982/88
(Barrett), was cited for the proposition that "reasonable
provisions for 'health and safety" must be measured against some
objective standard, and that a cause and effec~ relationship
between the perceived harm and the risk to health.and safety must
be established. In Union Grievance, GSB 9826/88 (Kates), the Board
said, at page 12: "However, we require cogent, dispassionate and
objective proof that an 'unnecessary' risk for extraneous and
irrelevant considerations has indeed been assumed. For example,
where is it .'carved in stone' that only ~he ratio of one
. 8
correctional officer to one inmate represents the only acceptable
balance for ensuring the safety of the employees that are assigned
escort duties? What other maximum.security institution, similar in'
nature to the Millbrook Correctional Facility, adheres to that
standard? Why is any deviation from that standard, provided there
is a proper weighing of the risks, an inappropriate safety measure?
Would the employer be alleviated from its responsibility under
Article 18.1 if the situation required mor% correctional officers
than the desired ratio?" In Moulton, GSB #230/88 (Watters), at page
12, the Board observed: "...it is not enough to show that .the
granting of a remedy might improve safety within the workplace.
Rather, the union must establish that the working conditions
suggest a real or serious possibility of harm." Stockwell, GSB
#1764/87 (Wilson), was cited for the proposition that the union is
not required to show actual harm has occurred from the impugned
actions of management. A real and serious risk of harm is
sufficient. Reference was made to W~atts/Kin~, GSB #1367/90
(Kaplan), where the Board held, at page 27: "In our view, it is not
unreasonable in a case where the union has demonstrated some degree
of risk to the Safety and health of employees to require the
employer to explain, if not justify, the 'necessity and
reasonableness of that employer-imposed risk .... in the absence of
any explanation why the investigators recommended an increase in
patrols to two per hour, or why this was later reduced to one per
hour, we find'that the increase is unnecessary and constitutes a
violation of Article 18.I."
In the instant case, we note that this grievance arose in
August, 1991, when the Ministry temporarily eliminated two post
positions at the jail. The settlement desired was that management
re-establish those post positions. On the evidence, we understand
that these post positions were re-established shortly after the
grievance was filed. The Ministry~ did not object to the grievance
proceeding on the union allegation that staffing was still
insufficient for health and safety reasons, and we had a full
airing of union concerns over the two-year period of our hearings.
!
We were unable to find any solid basis in fact for the'union
proposition that under-staffing put the Correctional Officers at
~ real and serious risk. There was no concrete evidence that when
an officer left his post to assist an officer at another post, a
risk to the staff was actually created. Similarly the occasional
missing of perimeter searches was not linked in any way o~ the
evidence to increased risk to staff.
We think there is an obvious potential risk to staff if a
back-up officer leaves the grill area while another officer is
inside a cell area, but it is the Correctional Officers'
responsibility to ensure that this does not occur and to report any
incident where it h~s occurred so it may be corrected. Management
does not require Correctional Officers to leave a grill area in
such circumstances and in fact forbids it. Similarly strip searches
should not be conducted by one officer alone, but any employee of
the jail can ac~ as back-up, and it is incumbent upon the officer
10
doing the search to insist on back-up or to report the situation
if back-up is requested and denied. There is certainly no evidence
that any officer was ever ordered to complete a strip search on his
own. Mr. McLagan, who testified he had seen it happen was in fact,
by observing it, acting as the back-up officer. Article 18.1 of the
collective agreement requires the employer and the union to co-
operate to the fullest extent possible in the prevention of
accidents and in the reasonable promotion of safety and health of
all employees. Unreported violations of standing orders would
appear to contravene the union's obligation in this regard. In
saying this, we make the assumption that if these occasional
violations of standing orders had been reported to management,
management would have taken steps to ensure there would be no
recurrence.
In result, we cannot find that the staffing arrangements at
the Chatham Jail pose a real or serious possibility of harm to the
staff and this grievance must be dismissed.
Dated at Toronto this 24~h day of Au§ust, 1996.
~ A. Barrett, Vice-Chairperson
W. Rannachan, Member
D. M6ntrose, Member