HomeMy WebLinkAbout1991-2968.Baron et al.93-02-12 ONTARIO EMPLOY~-$ DE LA COURONNE
- -- : CROWNEMPLOYEES DEL'ONTARIO ·
.... GRIEVANCE C,OMMISSlON DE
SETTLEMENT REGLEMENT
"BOARD DES GRIEFS
~,$0' OUNDAS STREET WEST, ~tJITE 2~00, TORONTO, oNTARFD. MSG ~ZB ,. TELEP',4?NE/TL~L~HONE.',(4~6) ~'6-13'88 '
780, RuE DUNDAS OUEST. BUREAU 2~00o TORONTO (ONTARIO). MSG 1Z8 ~ FACS. IMILE/T~'L/~COP~E : (.~ 16) 32~- ~396
2968/91, 2976/91
"'IN' THE MATTER OF AN ARBITIt~TION
Un, er
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN ".~.
OPSEU (Baron et al)
Grievor
. aaa._
The Crown in Right of Ontario
(Ministry of Co_m_munitY' & Social Services)
Employer.,
BEFORE: W. Kaplan'" Vice-Chairperson
P...Klym Member ;
M. O'Tooke' Member
FOR THE P. Munt-Madil
UNION Counsel
Ryder, Whitaker, Wright & Chapman
Barristers & Solicitors
FOR THE J. Smith ~.,
EMPLOYER CoUnsel
~ Legal Services .Branch'
Ministry of Co_~_m_unity & Social. Services
HE~RING January 22, 1993 - ~ .,,
Introduction
This case concerns nine somewhat differently worded grievances filed by
all of the full-time classified probation officers working in the Ministry's
Oshawa and Ajax offices. The §rievances are to the effect that the
Ministry's distribution 'of work within the Peterborough Area Probation
Services is unfair and is detrimental to the employees' health. The remedy
requested is that the workload be equalized throughout the Peterborough
Area.
The case proceeded to a hearing in Toronto at which time counsel for the
employer raised a preliminary objection. Employer counsel argued that
inasmuch as the grievances were about workload, the Board did not have
jurisdiction with respect to them as workload was an exclusive
management function assigned to the Ministry by the Crown Employees
Collective Bargaining Act. Union counsel argued that the Board did have
jurisdiction with respect to this case. It was not necessary to hear any
evidence for the purpose of determining this preliminary objection, and the
case proceeded directly to argument.
Union Argument
Union counsel began her submissions by :.providing the Board with some
background facts. The grievors provide Probation services to youth who
have terms of probation set by a judge pursuant to the Young Offenders ..Acct.
The grievors' workload is determined by the number of cases assigned, and
each case involves one young offender on probation. Six of the grievors
work in the Oshawa office, and the remaining three work in the Ajax office.
These two offices are part of the Peterborough Area for administrative
purposes.
ur{ion counsel made two arguments in favour of her Position that the Board
had jurisdiction .over these grievances... First; counsel submitted that the
workload 'in the Peterborough Area is being determined' 'in a'n unreasonable,
arbitrary and discriminatory fashion and, furthermore, that management is
acting in bad faith. Second, counsel argued that the employer was in
violation of Article 18.1 of the collective agreement insofar as it was not
taking reasonable provisions for the health and safety of the grievors.
Counsel advised the Board that she had provided' particulars of this health
and safety violation to employer counsel, and it was indicated to the Board
that further particulars would be forthcoming should the Board take
jurisdiction in this case. Counsel advised, in the meantime, that the
increased workload 'has adversely affected the health of some of the ·
grievors.
With respect to'the first ground, union 'counsel did not take issue With the
fact that management has the right to assign and organize work, but
submitted that this right was not unfettered, and 'it could, accordingly, be
subject 'to arbitral-review. In counsel'{ submission, the employer was
allocating work in such.a manner-So as t0 impose' an extraordinarily high
case load on the grievors. This case 10ad was· not, in counsel's view,
rationally connected to the employer's stated objectives, a'ncl was also
discriminatory inasmuch as the grievors had a higher caseload than other
probation officers in the Peterb0rough Area. Counsel also suggested that
the workload assignment was in bad faith because the employer has
established certain standards which it expects the grievors to meet, and
failure to meet these standards can result in discipline. While none of the
grie'vors had been disciplined for failing to meet these standardsl (which
was impossible given the workload), that P~tential did exist and it
illustrated, counsel suggested, t~he bad faith activities of the employer.
Moreover, in counsel's view, this liability for discipline made management's
action subject to arbitral scrutiny, and counsel referred the Board to the
_Bousquet 541/90 (Gorsky) decision as one of a number of authorities on
point,
Employer Argument
Employer counsel argued that this case was not about health and safety.
Rather it was about workload, and as the union conceded that workload was'
a statutory management prerogative, counsel urged the Board to dismiss all
nine grievances.
In .counsel's submission, the Board must, in reviewing its jurisdiction in a
case of this kind, ask itself what the fundamental nature of the grievances
before it actually is. In this case, counsel suggested that a review of the
grievances indicated that they were not about health and safety. Instead,
they were about workload. That this was the correct characterization of
the grievances was made apparent to employer counsel by the fact that the
remedy requested was an equalization of workload, not some other remedy
more readily associated with a breach of Article 18. t. Counsel conceded
that the grievances also referred to the workload as being detrimental to
health, but argued that they were, nevertheless, fundamentally about
workload.
Counsel cited a number of cases to the 8oard including Warden 1152/97
(Dissanayake). That case invo{ved a grievance alleging that the workload
was causing stress. Changes to the workload were sought as remedy. The
employer argued in Warden, as in the instant case, that the grievance should
be dismissed as inarbitrable. The union argued, as here, that the grievance
also alleged a violation of the health and safety provision of the collective
agreement, and so the Board had jurisdiction With respect to it. The Board
.in Warden found: ,
The Board agrees with. counsel ~for the grievor that' it is .-
·not essential that the grievance refer .specifically to a ..
particular article in the collective agreement or
· . provision in the Act before.it becomes arbitrable. Nor
are we unduly concerned that the grievance did not use
the Phrase "health and safety" and did not articulate a
health and safety issue' precisety. In that we recognize
that grievances are not written necessarily by legally
trained persons, the Board will not refuse to accept a
grievance merely because of technical defects or
imprecise language. All that is required is that .the true
nature Of the grievance must be communicated to the
employer.
...If the thrust of a'grievance is a health and safety issue'
Under article, i8.1, then in our respectful View that
grievance is arbitrable despite the fact that the
resolution of that grievance may necessitate an inquiry
relating to the employer's exercise of management
rights.
The issue her. e' then is,. does. the 'thrust or the central
issue in the grievance before Us relate to a health and
safety issue (at 2-3).
The Board in Warden determined that the grievance before it failed to meet
this test, and accordingly dismisSed it as inarbitrable. "
Employer counsel urged a similar result in the instant'case, and 'suggeSted
that following careful consideration it could not be said that the thrust of
the grievances before the Board related to a health and safety issue.
Accordingly, counsel argued that these grievances should be dismissed.
Counsel pointed out, however, that the Warden'. case was somewhat
different from the instant one in that the grievor in that case had' not made
6
his health and safety concerns known to the employer prior to the hearing
while those concerns had been made known in the instant case.
Counsel also referred to Union Grievance 0311/88 (Watters). In that case
the grievance specifically referred, among other things, to inadequate
staffing and a violation of article 18.1. That was, in counsel's submission, .a
different case from the instant one where the health and safety issue was
an add-on, and not part of the fundamental', issue in dispute, namely the ~
workload at the Oshawa and Ajax offices.
in conclusion, counsel suggested that it would only be necessary to deal~
with the union's allegations about management acting unreasonably,
arbitrarily, discriminatorily and in bad faith if the Board took jurisdiction
i'n the case, and then these allegations would best be dealt with in the
context of a full review of the merits.'
Union Reply
In reply, union counsel took the position that the Board had the right to take
jurisdiction on either of the two grounds advanced in argument. Simply put,
the Board coutd take jurisdiction on the basis of the union's claims aboL, t
management conduct given the 8ousquet decision, i-t could also
independently take jurisdiction given the fact that a health and safety
violation had been alleged. Counsel suggested that the cases relied on by
the employer supported the union, and pointed out that for the Board to take
jurisdiction over these grievances they need not specifically refer to
article 18.1. The employer was effectively put on notice when the
grievances were filed that health and safety was in issue, and there wa.,; no
question in this case of it being taken by surprise. Counsel suggested that
the Union Grievance decision was on all fours with the instant case, and
counsel noted that the Board readily took jurisdiction over a grievance
alleging that employee complement was adversely affecting " health and
safety.
Counsel referred the Board to one other decision, Jostman, .Cargill-Sim
1437/89 (Watters). In' that case the statement of grievance.referred to
Article 18.1, as well as to the employer failing to provide'the grievors With
reasonable working space "to the detriment of our health, family life, and',
work quality." The grievances continued: "Further, at our office, we are
forced'to work in a dangerously crowded an'd hostile environment under
continuing harassment by Ministry o¢ Labour employees and without
appropriate office services' or facilities, preventing us from providing good
service to our client groups, and lbrOducing'health-threatening stress and
anxiety" (at 1).. The employer objected that the grievances were
inarbitrable, and the 'Board dismissed th~t~ objection, it found that:
These grievances, on their face, assert a contravention
of article 18.1 of the collective agreement. Further they
refer, to certain working conditions which ccJuld
Potentially resutt in adverse health and safety
consequences. We do not think it essential that
grievances of this nature isolate particular threats or
physical encounters which ha, ye occurred, as article 18.1
· appears to contemplate situations wherein,grievances
can be pursued to prevent a risk from arising. In this
respect, we have been persuaded that the thrust of the
grievances are health and safety related. The fact .that
the, resolution of those issues may necessitate an inquiry
relating to the Employer's exercise of management rights'
does not serve to preclude the hearing of the
complaint .... (at 6-7)
Counsel argued that this case also applied,with respect to the instant, one,
and urged the Board to apply the .appropriate'principles found in it. In the
event that the Board did so, both parties requested that we remain seiz,ed
with respect to the merits.
Decision
Having carefully considered the evidence and arguments of the parties, we
have come to the conclusion that the employer's preliminary objection
be dismissed.
In our view, the grievances, on their face, allege a violation of the health
and safety provision of the collective agreement. Accordingly, the Board
must take jurisdiction with respect to them. We do not agree that the main
thrust .of these grievances, as written, is workload, although it is, of
course, possible that we might eventually reach that conclusion. However,
only by taking jurisdiction and hearing evidence and argument can this
matter be decisively determined. Very simply, the grievances allege that
management's actions with respect to staffing violate article 18.1. While
staffing is an exclusive management prerogative, health and safety
violations are properly before' the Board, and it is on this basis that we are
taking jurisdiction.
As was the case in Union Grievance we find that it is proper "to hear
evidence in respect of the allegation in order to determine if there is merit
to it. This is a question which, in our estimation, cannot be answered
without the presentation and consideration of relevant evidence. The fact
that staffing and complement may be part of management rights under
Section 18 of The' Crown Employees Collective Bargaining Act is not a bar
to the assessment of the health and safety complaint" (at 6). As is also
noted in Jostman, Cargill-Sim: "Ultimately, the Board will have to
determine whether [the grievances] have merit, and if so, whether we can
) p~ovide an appropriate remedy. The Employer will then be accorded a
further opportunity to argue as to the existence 'of any constraints on our
remedial jurisdiction" (at 7).
As a result of making this ruling, it is not .necessary for us to make any
findings' with respect to whether or not the Board has jurisdiction to
review exclusive management prerogatives where it is alleged that the
employer is acting in an unreasonable, arbitrary and discriminatory fashion,
as well as in bad faith.
The case shall reconvene on dates set by the Registrar.
DATED at Toronto this t2i:h day of February 1993.
William Kaplan
V i c¢~-. C ha irpe rson
Membe~
~. O'Toole
~ember