HomeMy WebLinkAbout1992-0566.Young.93-03-24
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ONTARIO 't, EMPLOYES DE LA COURONNE
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CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
.
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 2700, TORONTO. ONTARIO. M5G 7Z8 TELEPHONElTi~LePHONE (476) 326-7388
180. RUE DUNDAS OUEST BUREAU 2100, TORONTO (ONTARIO} M5G lZ8 FACSIMILE ITeLf!COPIE (416} 326-7396
566/92
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE S~TLEMENT BOARD
BETWEEN
OPSEU (Young)
Grievor
- and -
I The Crown in Right of Ontario
(Ministry of Health)
Emp1.oyer
BEFORE: W Kaplan Vice-Chairperson
M. Lyons Member
I D. Montrose Member
FOR THE J Paul
UNION Grievance Officer
Ontario Public Service Employees Union
FOR THE M Quick
EMPLOYER Counsel
Legal Services Branch
Ministry of Health
HEARING December 3, 1992
January 19, 1993
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Introduction
By a grievance dated April 10, 1992, Susan Young, a Registered Nursing
Assistant employed at the Whitby Psychiatric Hospital, grieves that she
was unjustly transferred and seeks, by way of remedy, return to her former
position The case proceeded to a hearing in Toronto, at which time
evidence and argument were heard.
In brief, it is the union's position that the employer has violated Article A
of the Collective Agreement as well as Article 50 6 1 The union alleges
that these provisions were violated as a result of the employer transfernng
the grievor to a new position upon her return from maternity leave The
employer took the position that there had been no violation of any
Collective Agreement provision and that the grievance should, accordingly,
be dismissed Before turning to the evidence and argument, it is useful to
set out the Collective Agreement provisions at issue in this case
ARTICLE A - NO DISCRIMINATION/EMPLOYMENT EQUITY
A 1 There shall be no discrimination practised by reason
of race, ancestry, place of origin, colour, ethnic origin,
citizenship, creed, sex, sexual orientation, age, marital
status, family status, or handicap, as defined in section
91 of the Ontario Human Rights Code.. (OHRC)
ARTICLE 50 - PREGNANCY LEAVE
50 6 1 A female employee returning from a
leave-of-absence under section 50 1 or 50 5 to the
ministry in which she was employed immediately prior
to such leave shall be assigned to her former position
and be paid at the step in the salary range that she would
have attained had she worked during the
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leave-of-absence
The Evidence
Ms. Young testified first. She has been employed at the Whitby Psychiatric
Hospital (hereafter "the Hospital") since August 1987 Prior to her
maternity leave the grievor worked in the Psychotherapy Unit. Ms Young
went on maternity leave in October 1991, and returned to work in April
1992 Prior to beginning her leave, Ms. Young discussed her impending leave
with Bernadette Bradley, the Nursing Manager of the Psychotherapy Unit
She advised Ms Bradley that she wished to return to that unit following her
leave Ms Bradley advised her that she wanted the grievor to return to that
unit, but that this could not be guaranteed, and that in the past, some
employees had been transferred to other units following maternity leave
The grievor testified that she liked working on the Psychotherapy Unit, that
she had cordial relations with Ms. Bradley and her co-workers, and that her
performance appraisal<\ were uniformly positive
During the grievor's maternity leave she was contacted by Ms Bradley, who
advised her that she would not be returning to the Psychotherapy Unit at the
conclusion of her maternity leave The grievor was advised in March 1992
by Ms Bradley that she was being transferred for staffing complement
reasons. The grievor then contacted Ms. Victoria Halpenny, the Nursing
Staff Coordinator, and the two met on March 27, 1992 Ms. Young made it
clear to Ms. Halpenny that she did not wish to be transferred. Ms. Halpenny
advised her that the transfer was due to staffing requirements and that
she, Ms Young, was the most logical person to be transferred from the
Psychotherapy Unit because she was on maternity leave The grievor
advised Ms. Halpenny that she did not wish to be transferred, and on April 3,
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1992 she sent her a letter to that effect. The letter stated, in part.
During our conversation, you informed me that it had
become apparent to you that P T U can reduce its staffing
number I was chosen to be transferred as I was
considered the most logical person because 1 had already
been away from the ward on a maternity and parental
leave You acknowledged and understood my not wanting
to be transferred, however you maintained that the
transfer would be taking place upon my date of return
I would like it to be so noted that: I am not in agreement
with the above noted transfer; and request to return to
the position on P T U , I held prior to my maternity leave.
;'~ Ms. Halpenny replied to this letter on April 3, 1992, and maintained her
decision to transfer the grievor, stating, in part, that she was "sorry that
you do not agree with your assignment following maternity and parental
leave "
Introduced into evidence were the minutes of a staff meeting held in the
Psychotherapy Unit on March 18, 1992 Under the heading "Staffing" the
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following appears "Would any staff like to volunteer to be transferred to
another ward ie STAT Our staff presently on leave will be returning and
will be reassigned unless another staff wishes to transfer" The word
"STAT" refers to the Short Term Assessment and Treatment ward The
reference to "our staff" was to the grievor None of the other employees on
the Psychotherapy Unit volunteered for the transfer
The grievor testified that she had worked in the Psychotherapy Unit for five
years and enjoyed her work. She feels that she has made a contribution to
the unit, and that she works well with patients in the unit. Indeed, she
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testified that Ms. Bradley expressed pleasure with her work performance on
many occasions. The grievor liked the fact that the Psychotherapy Unit is a
long-term treatment unit, for this provided her with an opportunity to
develop good working relationships with patients, and to assist them in
dealing with their problems and disabilities Employees assigned to the
Psychotherapy Unit provide more than conventional nursing duties, they also
help patients with hygiene, life skills, grooming and nutrition The grievor
testified that she found this work to be fulfilling
Upon her return from maternity leave the grievor was transferred to the
STAT ward She testified that she did not like working on this ward as
,:; much as her previous assignment, and that one distinguishing characteristic
was the fact that she is now involved in physically restraining patients
She did not have to do this in the Psychotherapy Unit. She also testified
that staff morale at her old ward was much higher than at her new ward,
and that her old ward also provided her with more opportunities for
professional growth The grievor told the Board that there was very little
"'1.. movement out of the Psychotherapy Unit.
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In cross-examination, the grievor agreed that it was possible that when she
was hired she was told that there was a possibility that she would be
transferred from one ward to another Ms Young was shown a copy of her
position specification and it was pointed out to her that it refers to 122
Psychiatric Nursing Assistant ("PNA") positions at the Hospital The
grievor agreed that she occupied one of these positions, and also agreed
that the Hospital has, in the past, transferred employees in the case of
staff shortages, because of patient numbers and other factors relevant to
patient care Ms. Young testified that anyone who is hired as a Psychiatric
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Nursing Assistant can be assigned to any ward in the Hospital to meet
health care needs.
The grievor was asked some questions about the Psychotherapy Unit, and
she testified that many of the patients on the ward had been voluntarily
admitted By and large, these patients suffered from personality disorders
such as depression The average length of stay for these individuals is
eight months Psychiatric Nursing Assistants on the unit work with these
patients as either the primary or associate nurse, and they are assigned to
patients for the entire period of their stay in the unit. Ms. Young agreed
that establishing a relationship with these patients was critical to their
therapy
There are now three Psychiatric Nursing Assistants in the Psychotherapy
Unit, and one nurse Before the grievor went on maternity leave there were
.- four Psychiatric Nursing Assistants assigned to the unit. In terms of
seniority, the Qrievor and one of the other Psychiatric Nursing Assistants,
Bev Moran, have equal hospital seniority as they began work on the same
day However, the grievor has more Psychotherapy Unit seniority than Ms
Moran
Ms. Young testified that to the best of her knowledge she was not replaced
while on maternity leave, and she agreed that one of the reasons provided to
her for her transfer was the fact that the Hospital determined during her
leave that it could function quite well with a lower unit complement. Ms
Young did not recall Ms Bradley advising her that her impending transfer
was because of ,patient needs, but she did recall Ms Halpenny' telling her
before she returned to work that she was the most logical person to be
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transferred as she was on maternity leave Ms. Halpenny also told her that
this transfer made sense for reasons of patient care including nursing
continuity Ms Young took 1 7 weeks of maternity leave followed by a
1 O-week parental leave Ms Young agreed with employer counsel that
continuity in patient care was important.
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The grievor was shown a copy of the Hospital's Staffing Policy It provides,
in part.
When an employee's return is indeterminate~ (more than
four (4) weeks) their time will be recorded in the
Nursing Office. Upon return to duty the employee will be
assigned according to needs and may spend" some time on
float. This applies to Maternity Leave also, as return to
the same ward is not guaranteed.
The grievor was not, however, familiar with this document.
The grievor testified that she was given a choice of wards to transfer to,
and stated that she is doing a good job on the STAT ward She is earning the
same pay, and has the same classification and seniority
in re-examination, the grievor testified that wilen she left on maternity
leave the Hospital knew the exact date of her return.
Ms. Victoria Halpenny testified on behalf of the Hospital Ms. Halpenny is
the Nursing Staff Coordinator, and has held that position for ten years. She
has thirty-four years of nursing experience, and she is responsible for
coordinating staffing throughout the Hospital This responsibility includes
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recruitment, interviewing, selection, assignment and transfers
When hiring employees Ms Halpenny advises them that they are not hired
for work on a particular ward, but could end up working anywhere in the
Hospital on any shift. The grievor was hired as a Psychiatric Nursing
Assistant, and Ms. Halpenny testified that there are 122 such positions in
the Hospital
Introduced into evidence was an extract from the Ontario Manual of
Administration It defines "position" as
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A grouping of duties and responsibilities
* established by management, and
* performed by an individual or group of individuals with
a specific organizational unit; and
* established in the IPPEBS
Ms. Halpenny was familiar with this definition, and she also identified the
Hospital's Staffing Policy earlier introduced Into evidence
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Ms Halpenny is responsible for coordinating staffing while employees are
on leave, and she does so by considering patient and ward needs, the number
of staff available and other relevant factors In her experience, staff on
leave return to the ward they were working on prior to their leave
approximately fifty percent of the time In general, maternity leaves last
for 11 9 days. Four weeks prior to the end of the maternity leave, an
employee can request an additional ten weeks of leave, and this period can
be extended one more time for a further ten weeks. In Ms. Halpenny's
experience, employees frequently ask to extend their leaves, although
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sometimes they ask to come back earlier than originally expected Ms.
Halpenny testified that she applies the same principles in dealing with all
types of leave requests.
Ms. Halpenny was asked about "multi-incumbent" positions, and she
testified that these are nursing assistant positions for which nursing
assistants can be interchangeably assigned in order to meet Hospital needs
Ms Halpenny is required to transfer staff on a daily basis, although
transfers of permanently assigned staff are much less frequent. In her
view, it is important to have flexibility in assigning employees, and if
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employees like the grievor were permanently assigned to a specific ward
she would lose that flexibility
Ms. Halpenny testified about the Psychotherapy Unit. Many of the patients
on that unit suffer from severe psychological problems, and some of them
are psychopaths Nursing Assistants assigned to that unit do a lot of
one-to-one care, and in her experience the average patient remains on that
.., unit for nine months. She testified that it can take a long time for patients
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to develop trust in nursing staff, and that the situation in the
Psychotherapy Unit is somewhat different than elsewhere in the Hospital
where the need for continuity in nursing care is slightly less important.
Ms Halpenny recalled discussing the matter of the grievor's leave prior to
its commencement. She testified that the Hospital originally intended to
replace the grievor while she was away, but after the grievor objected, and
after she persuaded the Hospital that it could manage without hiring a
replacement, the decision was reached to do just that As it turned out, the
Hospital then learned that it could function with one less employee, and so
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for this reason as well as budgetary concerns, the decision was made to
transfer one employee to a different ward Ms Halpenny described her
March 27, 1992 meeting with the grievor, at which time she advised her
that since she had been away for approximately eight months, she would be
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reassigned. Ms. Halpenny told the Board that the grievor was not treated
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any differently than any other employee who might have been away on leave,
such as, for example, an employee away on educational leave
In cross-examination, Ms Halpenny testified that she has transferred
employees returning from maternity leave on many occasions Ms Halpenny
was aware that the grievor's co-workers in the Psychotherapy Unit were
,.'; given the opportunity to voluntarily transfer, and she agreed that the
grievor was not given this opportunity Ms. Halpenny was then asked how
she could say that grievor was treated the same as everyone else, and she
replied that she was treated the same as everyone else returning from
leave
Ms. Halpenny was asked what she would have done if the grievor had not
been away on maternity leave and the decision was reached to reduce the
complement by one on the Psychotherapy Unit. She replied that she would
have looked at patient needs and nursing skill levels, and she would have
also considered seniority in making her selection If the two most junior
employees had equal hospital seniority, then Ms. Halpenny would have
probably looked at ward seniority in deciding which of the two should be
reassigned Ms. Halpenny, however, did not think that she had to take this
factor into account when she made this decision because the grievor was
not working on the unit at that time
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Ms Halpenny testified that it takes some weeks for a Psychiatric Nursing
Assistant to effectively separate from his or her nursing relationships, and
\ this was another factor influencing her decision to transfer the grievor
upon her return
In re-examination, Ms. Halpenny testified that the most important factor in
transferring a Psychiatric Nursing Assistant was patient care, not
seniority
Mr Carl Sumner also testified on behalf of the employer Mr Sumner is the
Regional Personnel Administrator He is based in Whitby, and has more than
"...; seven years of experience in the Ontario Public Service -Mr Sumner
testified generally about the purpose of the classification system, and the
class standard for the Psychiatric Nursing Assistants was introduced into
evidence He also reviewed the grievor's position specification, and
testified that it was a multi-incumbent position, and that there were 122
such positions at the Hospital, although there was variance with respect to
specific assignments. This position specification provided the employer
and the employee with a general-description of duties and responsibilities,
but also ensured that there was operational flexibility
Mr Sumner was asked about Article 50 6 1 of the Collective Agreement, and
he testified that he interpreted the word "position" in that article as any
Nursing Assistant position He testified that this has been the Hospital's
consistent interpretation of the Article, and that all new recruits are
advised that they could be assigned to any job in the Hospital. Mr Sumner
testified that he arrived at this interpretation by his experience with the
Collective Agreement, and he made reference to other uses of the word
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"position" throughout that Agreement. He also arrived at that
interpretation through his review of the Crown Employees Collective
Bargaining Act and the Manual of Administration
Union Argument
Mr Paul began his argument with the submission that the employer had
failed to properly interpret Article 50 6 1 of the Collective Agreement, and
that it had, moreover, violated Article A 1 Turning to his second
submission first, Mr Paul argued that the evidence established a violation
of Article A.1 In his view, the employer had directly discriminated against
the grievor in transferring her upon her return from maternity leave, it had
engaged in adverse impact discrimination by treating her the same as other
employees on leave, and had also improperly exercised its discretion in its
interpretation of the maternity leave provisions. As the underlying
authority for a number of his propositions, Mr Paul referred the Board to
Kimmel/Leaf 1391/90 (Kaplan)
Mr Paul noted that while the grievor was away on maternity leave, her
co-workers in the Psychotherapy Unit were given the opportunity to
volunteer to transfer The grievor was not given this opportunity, and a
transfer was, in the result, imposed on her because she was a woman and
because she had been pregnant. Mr Paul pointed to the Hospital's Staffing
Policy and argued that it was, on its face, discriminatory and constituted
direct discrimination Further evidence of direct discrimination was, in Mr
Paul's submission, provided by the grievor who testified that Ms. Halpenny
advised her that she had been chosen for the transfer because she was on
maternity leave
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With respect to adverse impact discrimination, Mr Paul argued that it too
had been established in evidence The grievor was selected for transfer
because she was on maternity leave A penalty was, accordingly,
associated with the status of being a woman on maternity leave, and none
of the other employees in the Psychotherapy Unit were subject to that
penalty Indeed, the other employees, in Mr Paul's submission, received
preferential treatment as they were accorded the opportunity to volunteer
to transfer, while the grievor was simply told that she was being
transferred Instead of accommodating the grievor, the employer
transferred her, and this, in the union's submission, violated Article A 1
With respect to improper exercise of discretion, Mr Paul argued that the
employer had fettered- its discretion, and he referred the Board to the
Kuynties 513/84 (Verity) decision That decision sets out four factors
which the employer must consider in exercising discretion, and these
require, among other things, that the decision be made "in good fait~ and
without discrimination," and that consideration be "given to the merits of
the individual application under review" Mr Paul suggested that the
decision in the instant case did not meet the requirements of the Kuynties
.~. decision in that it was discriminatory and that the Hospital had not given
proper consideration to the grievor's position
Ultimately, with respect to the violation of Article A 1, Mr Paul suggested
that the important question to ask was where would the grievor be today if
she had not been away on maternity leave when the decision to transfer her
was made?
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With respect to the alleged violation of Article 50 6 1, Mr Paul argued that
a plain reading of that provision indicated that the parties intended that
women on maternity leave not suffer in any way from having gone on
maternity leave upon their return to work In Mr Paul's submission, to give
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effect to that intention, the words "her former position" must be
interpreted to mean the particular job that the woman held before leaving
on maternity leave
In the instant case, the grievor's "former position" was the job she held in
the Psychotherapy Unit. Although employer witnesses testified that there
were '22 Psychiatric Nursing Assistant positions at the Hospital, Mr Paul
argued that the evidence demonstrated that these positions were not the
same as an employee's former position. While the employer could and did
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transfer employees to meet operational needs, for example if an employee
was sick and another employee was needed to fill in, the evidence also
established that employees occupied permanent positions on assigned
wards The grievor, for example, had been in her job for some years. This
job was, accordingly, her "former position "
Mr Paul referred the Board to the Furniss 602/86 (Slone) decision in
support of his submissions with respect to the proper interpretation of the
term "former position" The Furniss case concerned the meaning to be given
to the word "position" in the context of a claim made by a seasonal
employee who grieved that he was not recalled to his "position" Unlike the
instant case, the union in Furniss urged that the Board, again in the context
of the seasonal recall provisions of the Collective Agreement, adopt a broad
definition of the word position and find that an employee who occupied
essentially the same job in three different provincial parks over the course
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of three consecutive summer seasons had a right to return to his "position"
The employer in Furniss, like the union in the instant case, urged that the
Board adopt a narrow interpretation of the word "position," and argued that
it referred to a specific location within a specific organizational branch
The Board in Furniss reviewed the pros and cons of each party's position at
some length in its reasons for decision. What is important for the instant
case, however, is that this discussion focused on each party's interests
with respect to the operation of the recall provision. Both party's in
Furniss referred the Board to other Collective Agreement provisions where
the word "position" was used. After reviewing those provisions the Board
concluded that the word "position" was not "used in all contexts to mean
precisely the same thing It is not a term of art. One can draw support for
both competing positions from other Articles within the Collective
Agreement, and we therefore find this approach to be not too helpful" (at 9)
The Board also found that the definition of the word "position" in the Manual
of Administration was of no assistance to it in interpreting the recall
provision at issue in that case
Mr Paul urged the Board to follow the approach taken In Furniss, and
interpret the word "position" within the context of the maternity leave
provisions not within the context of the Collective Agreement considered
as a whole Mr Paul suggested that Mr Sumner's evidence was simply his
opinion, and that the Board in this case, as in Furniss, should not, and could
not be bound by the interpretation of the word "position" found in the Manual
of Administration, or in the Hospital's policy
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In Mr Paul's view, the jurisprudence supported the proposition that the
word "position" has to be interpreted within the factual context at issue in
each particular case (see Union Grievance 1623/87 (Samuels)) In the
instant case, Mr Paul argued that the evidence established that the grievor
worked in a particular "position" and had done so for some years This was
a permanent position in the sense that the grievor returned to exactly the
same ward and the same duties and responsibilities day after day, year
after year It did not make any sense, in his submission, in these
circumstances to suggest that the grievor's position was any of 122 PNA
positions lound throughout the Hospital Indeed, the fact that the Hospital
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did have specific positions was illustrated by the fact that the grievor was
transferred to one such position, the STAT ward, upon her return from
maternity leave, and that this transfer was a permanent one Further
evidence of the permanent nature of various positions was provided by Ms.
Halpenny's evidence that transfers from the Psychotherapy Unit are not a
regularly occurring event, and that one important factor in making these
transfers was seniority Very simply, in the union's submission, the
grievor's position was on the Psychotherapy Unit, and it was to that
position that she should have been returned to following her maternity
leave
Mr Paul argued that the whole purpose of Article 50 6 1 was to ensure that
female employees did not suffer as a result of taking maternity leave That
is why it was written, and to uphold the employer's position with respect
to the word "position" would completely undermine the purpose of the
provision, for such a result would be contrary to its remedial intention
Following the h~aring, Mr Paul supplied the Board with relevant extracts
from the Employment Standards Act In 1990, the relevant Employment
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Standards Act provision stated that.
An employee who intends to resume her employment on
the expiration of a leave of absence granted to her under
this Part shall so advise her employer anQ on her return
to her work her employer shall reinstate the employee to
her position or provide her with alternative work of a
comparable nature at not less than her wages at the time
her leave of absence began and without loss of seniority
or benefits accrued to the commencement of her leave of
absence
On January 1, 1991 a new provision came into effect, and it was the
provis~onin effect at the time the grievance was filed and heard It
provides
The employer of an employee who has taken pregnancy
leave or paternal leave shall reinstate the employee
when the leave ends to the pOSition the employee most
recently held with the employer, if it still exists, or to a
comparable position, if it does not.
Mr Paul pointed out in his argument that the Collective Agreement provided
simply for the right of a female employee to return to her position
following maternity leave, not to any comparable position The applicable
Collective Agreement did not provide for a return to one's classification
following maternity leave, as was the case in the prior Collective
,Agreement. This change was further evidence of the intention of the
parties Mr Paul asked the Board to find that the Collective Agreement had
been violated, and to make an order returning the grievor to the
Psychotherapy Unit. Mr Paul requested that the Board remain seized with
respect to the implementation of Its award
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Employer Argument
Employer counsel argued that the words "former position" did not refer to a
specific job, but referred to all 122 Psychiatric Nursing Assistant
positions within the Hospital In counsel's submission, the Furniss decision
!i directly applied to the instant case. Counsel argued that that decision
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stood for the proposition that where the duties and responsibilities of an
individual were, by and large, the same, then notwithstanding the fact that
that individual worked in two or more different worksites, he or she was
still working in the same position Applying this principle to the instant
case, counsel argued that the grievor was still, by and large, doing the same
} job as she had in the past, and that, accordingly, she was occupying the
same position that she had occupied in the past. Counsel urged the Board to
dismiss the grievance on this basis alone
Employer counsel also referred the Board to the Smith 2315/87
(Oissanayake) award, where the Board held that in "determining whether a
position is the grievor's former position some latitude must be allowed for
minor differences In our view the appropriate test is whether or not the
substance of the duties and responsibilities are sufficient similar This
will be a question of fact in each case (at 9) Simply put, in counsel's
submission, this case stood for the proposition that so long as two jobs
were substantially similar in their duties and responsibilities, they
qualified as one and the same "former position" (See also Anderson 471/86
(Roberts), and Brand 1516/87 (Stewart)) Counsel argued that these and
other cases stood for the proposition that the Board has consistently given
the word "position" a broad interpretation, and that it should also do so in
the instant case Counsel suggested that this approach was also the one
followed in the private sector indicating its general acceptance and
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applicability (see Re De Havilland Aircraft of Canada Ltd. and UAW. Local
673 5 L.A.C. (3d) 147 (Palmer)
In addition, counsel argued that as a general matter, the Board should
interpret the word "position" in a consistent manner, and one aid to its
proper interpretation was its use elsewhere in the Collective Agreement.
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Counsel referred to its use both in the recall provisions for seasonal
employees, as discussed in the case law, as well as its use in the health
and safety provisions and in the surplus provisions By way of example,
~ counsel suggested that if the union's narrow interpretation of the word
"position" was found to govern, then it would act to the detriment of
surplused employees under Article 24 16 1 And this, counsel suggested,
would not reflect the intention of the parties
With respect to the allegation of discrimination, counsel argued that the
evidence established that there had been no discrimination in this case.
The grievor had been returned to her position, and so she could not claim
that she had been discriminated against on the basis of gender Counsel
argued that the evidence established that the grievor had been treated no
differently than anyone else on leave, and so, in her view, the claims of
direct and adverse impact discrimination must fail Counsel further argued
that the grievor had been treated in accordance with the employer's long
established policy, and that she was transferred for legitimate operational
needs Nevertheless, her position did not change
Union Reply
In reply, Mr Paul argued that the Board found in Furniss that the word
"position" was not a state-of-the-art term, and that it had to be
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interpreted within the context of each different article of the Collective
Agreement. It would be interpreted one way for the recall rights of
seasonal and surplused employees, and another way for determining the
rights of employees returning from maternity leave And one reason in
support of these differing interpretations was the fact that the recall
rights of seasonal and surplused employees were based on seniority, while
those of employees returning from maternity leave were not. This reason
alone, in Mr Paul's submission, justified the two different approaches to
interpreting the term. Seasonal and surplused employees were in a much
different situation than employees on maternity leave, for employees on
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maternity leave are guaranteed their job upon their return to work.
Decision
Having carefully considered the evidence and arguments of the parties, we
have come to the conclusion that the grievance must be upheld In our view,
the employer h~s failed to properly apply Article 506 1 of the Collective
Agreement. We find that the words "former position" refer, in the context
of this Article and the facts of this case, to the specific position held by
the grievor prior to her maternity leave
In general, we agree with employer counsel that the rUles of statutory
interpretation favour assigning the same meaning to the same word used in
the same statute In general, this prinCiple undoubtedly applies to the
construction of collective agreements We do not, however, find that it
applies in this case because a review of the use of the word "position"
throughout the Collective Agreement leads one inescapably to the
conclusion that it is used to mean different things in different sections.
This is hardly surprising given the size of the bargaining unit, and the
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countless positions throughout the Ontario Public Service Moreover, it is
hardly surprising that the word should mean one thing to an employee
returning to her job from maternity leave and another thing to a seasonal
employee relying on his or her seniority rights to return to work at the
start of another season
Our finding in this case is buttressed by the change in language in the
Collective Agreement, which in turn reflects the changes in the Employment
Standards Act. Article 50 6 1 of the predecessor Collective Agreement
(January 1, 1989 to December 31, 1991) provides that "A female employee
returning from a leave-of-absence under section 50 1 or 50 5 to the
"~;. ministry in which she was employed immediately prior to such leave shall
be assigned to her former classification. " (emphasis ours) Article
50 6 1 of the Collective Agreement applicable in the instant case (January
~
1, 1992 to December 31, 1993) provides that "An employee returning from a
,
leave-of-absence under section 50 1 or 50 5 to the ministry in which she
was employed immediately prior to such leave shall be assigned to her
former position " (emphasis ours) Obviously, the word "classification"
was changed to the word "position" for a reason, and that reason must be to
enhance the protections afforded to pregnant employees taking maternity
leave Moreover, the conclusion is inescapable that the change was made as
a result of the raising of the minimum standards in the Employment
Standards Act. The law now requires that an employer reinstate an
employee returning from her maternity leave to her position if it still
exists. We found, in the instant case, that Ms. Young's position continues to
exist and that the Collective Agreement mandates that she be returned to
it
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(. 22 (
~ .
Our interpretation of the Collective Agreement is supported by the Board's
.
jurisprudence In Smith, referred to by employer counsel, the Board held
A Classification includes a bundle of duties and
responsibilities, usually requiring similar qualifications,
skills and abilities A classification is broader than a
position A single classification may encompass a
number of positions. Each position may include some
combination of the duties from within the bundle of
duties in that classification Thus two employees may
be identically classified but may be performing
completely different duties In article 3 20 1 the
employee's right to recall is to his "former position"
The word "classification" is one well known to parties
and it has been used in numerous other places in the
collective agreement. If the parties intended to extend a
right of recall to any position in the classification in
which the employee had previously worked different
- language would have been used The article as it is
presently worded cannot reasonably be interpreted in
that manner (at 8)
0
likewise, we find in the instant case that in referring to the employee's
former position, the parties intended to refer to a specific position where
such a position can be associated with a particular employee
Obviously, there WIll be cases where no such position can be identified as
belonging to a particular employee These cases will, therefore, to some
measure, turn on their par.ticular facts. The facts of the instant case make
it clear that the grievor had a specific job And it was that job that she
should have been returned to following the conclusion of her maternity
lecJVe
--
( 23 (
~ .
Our finding is explicitly supported by the wording of Article 50 6 1 and the
I grievance can be upheld on this basis alone However, it is necessary in
I this case to make some further findings with respect to Article A That
provision guarantees employees freedom from discrimination on the basis,
among other grounds, of gender Article A requires a purposive
interpretation, and its purpose is to eliminate discrimination on prohibited
grounds in the workplace. We cannot help but find In this case that the
grievor was directly discriminated against on the basis of her gender Had
she not been a woman, and had she not been on maternity leave, the
employer would not necessarily have transferred her to a different job It
might have transferred her, but if it did, the evidence indicates that it
I" would not have done so on prohibited grounds Moreover, had the grievor not
"-
been a woman, and had she not been on maternity leave, she would have been
afforded the same opportunity as everyone else who worked on the
Psychotherapy Unit to volunteer to transfer to another ward. She was not
given that opportunity and the evidence indicates that she was not because
she was away on maternity leave Accordingly, we are left with no choice
but to find a violation of Article A on the grounds of direct discrimination
against the grievor
It is also necessary in this case to make some findings with resp~ct to
adverse impact discrimination The Hospital in this case has a policy that
it uniformly applies with respect to return from leave The policy applies
to everyone, and it is to the effect that upon return from leave employees
mayor may not be assigned to their previous wards. This policy is neutral
on its face in that it applies to everyone equally However, the policy has
an adverse impact on women who become pregnant and go on maternity
leave Protection from discrimination based on gender is guaranteed in
~ .~. ~._.~
(, 24 <..
f .
Article A. The Hospital's policy, because of its adverse impact on women,
violates that provision, and may fail to meet the mint mum standards set
out in the Employment Standards Act A finding of adverse impact
discrimination imposes a duty on the employer to accommodate to the point
of undue hardship. In the instant case, the employer's accommodation
obligation is spelled out in Article 50 6 1 It requires the employer to
return the grievor to her former position at the conclusion of her maternity
leave Our award, therefore, does nothing more than enforce the bargain
reached by the parties.
Very simply, the Hospital's return from leave policy impacts on employees
;(i: on maternity leave because they are women, and the parties have agreed
that there w!ll be no discrimination based on gender The policy is in
violation of the Collective Agreement, and to the extent that it has an
adverse impact on women returning from maternity leave we declare it to
be of no effect.
~~ It is not necessary, given our disposition and given the facts of this case,
to make any findings with respect to the exercise of the employer's
discretion However, it is appropriate to make some general findings with
respect to the employer's conduct in this case there is no evidence of any
bad faith on the part oJ Ms. Halpenny or any Other member of management.
This is a case of first impression, and the evidence indicates that the
Hospital applied its long.,.established policy in the manner that it had been
applied without incident or complaint on countless previous occasions. It
was clear from her evidence that Ms. Halpenny made decisions in what she
considered to be the best interests of the Hospital
- _.
(,," (
"';''- 25
--:;,. 1. -;
Additional Observations
A few additional observations are in order It is important to bear in mind
that maternity leaves are not like other leaves, and notwithstanding the
employer's Staffing Policy, they should not and cannot be treated in the
same way Maternity leaves are special because of the detailed provisions
of the Collective Agreement, and because of the overriding implications of
Article A.
It is also worth noting in passing that the evidence did not establish that
returning the grievor to the Psychotherapy Unit would have had any
damaging effect on patient care In her evidence in chief, Ms Halpenny
spoke about the needs of patients in the Psychotherapy Unit, and testified
that continuity in patient care was only slightly more important on that
ward than on other Hospital wards. Indeed, there was no evidence before us
that there would have been any damaging consequences of returning the
grievor to her position. While the evidence indicates that it can take
several weeks to separate from a nursing relationship, the evidence also
indicates that the Hospital knew when the grievor was coming back and so
could have planned for this in advance
Conclusion
For the foregoing reasons, the gnevance is upheld The Hospital is directed
to reinstate the grievor to her former position on the Psychotherapy Unit
with the ward seniority she would have had had she been returned to that I
unit at the conclusion of her maternity leave Put another way, she is to
suffer no loss of seniority for either the period that she was away from the
ward while on maternity leave or the period from her return to work at the
Hospital to the date of the implementation of this award
( 26 (\,
, ;'>.j I~'
Implementation of this Award
We foresee certain difficulties with respect to the implementation of this
award
-
In making this award we are not, obviously, directing the employer to
increase the staff complement on the Psychotherapy Unit. All we are doing
is finding that the Hospital should have returned the grievor to her former
position on that unit at the conclusion of her maternity leave A t that time
the employer would have had every right to transfer one or more employees
-
The Hospital still has that right. Indeed, the Union never disputed the
employer's entitlement to reduce complement on this ward The focus of
its dispute with the employer was the manner in which that decision was
executed
The Hospital may now decide who to transfer out of that ward, but it
cannot, in our view, make that decision in such a manner so as to
discriminate against the grievor for being away while on maternity leave
It must make that decision as if the grievor had not been away And it must
make that decision as if the grievor had returned to the ward following the
completion of her maternity leave Accordingly, we direct the Hospital to
reinstate the grievor to her former positionio the Psychotherapy Unit with
the ward seniority she would have had had she been properly returned to her
former position in the first place The Hospital is directed to implement
this award within four weeks of its date of issue (and in that way have
enough time in order to properly prepare the patients in the Psychotherapy
Unit for this change) or as mutually agreed upon by the parties
(;:"~ (:" \
27 ........'
. ~~ (j.
We remain seized with respect to the implementation of this award
DATED at Toronto this 24th day of March, 1993
IN IL
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"I Dissent" (dissent to follow)
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D Montrose
Member
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