HomeMy WebLinkAbout2015-2948.Chiba.17-01-04 Decision
Crown Employees
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GSB#2015-2948, 2015-2949, 2016-0010
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Association of Management, Administrative and
Professional Crown Employees of Ontario
(Chiba/Argyropoulos) Association
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The Crown in Right of Ontario
(Ministry of Attorney General) Employer
BEFORE Gail Misra Vice-Chair
FOR THE
ASSOCIATION
Kelly Doctor
Goldblatt Partners LLP
Counsel
Marisa Pollock
Goldblatt Partners LLP
Counsel
FOR THE EMPLOYER Susan Munn
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING December 15, 2016
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Decision
[1] The Ministry of the Attorney General (the “Employer”) made a motion pursuant to
Rule 3 of the Grievance Settlement Board (“GSB”) Rules of Procedure to have three
disputes heard together. The two complainants in the disputes worked as Hearings
Officers in the Toronto Court Services Division of the Ministry of the Attorney General.
[2] On May 25, 2015 AMAPCEO (or the “Association”) filed a formal dispute on
behalf of its member, Charlotte Chiba, claiming that the Employer did not have just
cause to give Chiba a letter of reprimand following receipt of a complaint by a client
about comments Chiba had made in an endorsement she had issued. On February 5,
2016 this dispute was referred to the GSB for arbitration.
[3] On September 10, 2015 the Association filed another formal dispute on Charlotte
Chiba’s behalf, claiming that the Employer did not have just cause to give Chiba a three
day suspension for having allegedly harassed Argyropoulos and for having caused a
poisoned work environment. This dispute was also referred to the GSB for arbitration
on February 5, 2016.
[4] The parties agreed to the appointment of Vice Chair Bram Herlich to hear the two
Chiba disputes, and on August 22, 2016 he issued a short decision regarding
production issues in one of the disputes. Following that interim decision, near the end
of August 2016, the parties engaged in a day of mediation with Vice Chair Herlich. The
disputes were not resolved and will be proceeding to be litigated on dates that have
been set in March and April 2017.
[5] On September 11, 2015 the Association filed a formal dispute on behalf of its
member, George Argyropoulos, claiming violations of various articles of the collective
agreement, various workplace policies, and the Workplace Discrimination and
Harassment Prevention (“WDHP”) Policy. In essence, the claim is that the Ministry of
the Attorney General failed to protect Argyropoulos from harassment by his coworker,
Charlotte Chiba, and failed to provide him with a safe and harassment-free workplace.
There are many allegations, but for the purposes of this motion, these are the most
relevant. On April 6, 2016 this dispute was referred to the GSB for arbitration. The
parties agreed that I would hear the Argyropoulos dispute, and the first day of hearing
was held before me on September 13, 2016. I am seized of the Argyropoulos dispute.
[6] The Employer seeks to have the Argyropoulos and Chiba disputes heard
together pursuant to Rule 3 because a number of Argyropoulos’ allegations are about
Chiba’s behaviour towards him, and, as already noted, the Employer has disciplined
Chiba with a three day suspension as a result of its investigation into his allegations. A
review of the Argyropoulos allegations suggests that he is relying on incidents that
occurred on April 1, May 8, May 20, June 19, and June 29, 2015, which he
characterizes as harassment by Chiba. He also has numerous allegations regarding
the Employer’s failure to properly handle his complaints about Chiba.
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[7] According to the Employer, the incidents of May 20, June 19 and June 29, 2015
had not been part of Argyropoulos’ original WDHP complaint and investigation, and
therefore had not been part of what the Employer had relied upon in its decision to
discipline Chiba. The Employer also relies on a reference in the Argyropoulos
documents that suggests that a comment Chiba is alleged to have made in October
2014 may also be in issue.
[8] There have been various exchanges between counsel on the Chiba matters, and
while it appears that Chiba concedes some aspects of the allegations, she disputes the
rest. As such, some evidence would have to be tendered by Argyropoulos in Chiba’s
three day suspension dispute arbitration. Chiba may also testify in her own defence in
respect of the Argyropoulos allegations.
[9] Argyropoulos has nothing to do with Chiba’s dispute as it relates to the letter of
reprimand that she received.
[10] In Argyropoulos’ dispute arbitration the Association will bear the onus of
establishing that he experienced workplace harassment by Chiba, and perhaps one
other person, and that the Employer did not do enough to protect him or to maintain a
harassment-free workplace. In this regard, the Employer asserts that it may have to call
Chiba as a witness to establish what happened.
[11] It is on the basis that there would be some common evidence that would have to
be called in both the Argyropoulos and Chiba disputes that the Employer seeks to have
the matters heard together. It argues that there are facts in common, and the relief
requested in both cases arises out of the same sets of circumstances. According to the
Employer, in making this motion, it is simply asking me to make an evidentiary ruling. It
wishes to avoid conflicting findings of fact should the two cases proceed separately. It
argues that hearing the disputes together would eliminate the risk of inconsistent
findings of fact, would save time, and would enhance the integrity of the GSB’s
proceedings.
[12] The Employer asserts that it is important from a labour relations perspective that
the Board speak as one, and that the possibility of having conflicting findings of fact by
two Vice Chairs of the Board would decrease the integrity of the Board’s processes.
[13] The Employer put the Board and the Association on notice that even if the two
matters were to be heard together, there may be further procedural issues to be
addressed as there is another outstanding AMAPCEO dispute filed on Chiba’s behalf
that will likely be referred to the Board, and which the Employer will likely argue should
also be heard with the two Chiba matters that are already in question in this motion.
Some aspect of the new matter also involves Argyropoulos, so the Employer contends
that his evidence may be necessary.
[14] The Employer relied on the following decisions in making its arguments: Ontario
Public Service Employees Union (Upson) and Ministry of Community Safety and
Correctional Services, 2013 CanLII 56967 (ON GSB)(Harris); Ontario Public Service
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Employees Union (McClelland/Ward) and Ministry of Community Safety and
Correctional Services, 2013 CanLII 73996 (ON GSB)(Briggs); Ontario Public Service
Employees Union (Moore et al) and Ministry of Community Safety and Correctional
Services, 2014 CanLII 48017 (ON GSB)(Nairn); Ontario Public Service Employees
Union (Ewing) and Ministry of Community Safety and Correctional Services, unreported
decision in GSB #2009-2078, November 28, 2011(Briggs); Association of Management,
Administrative and Professional Crown Employees of Ontario (Bhattacharya) and
Treasury Board Secretariat, unreported decision in GSB #2014-1191, December 1,
2015 (Anderson).
[15] Rule 3 of the GSB’s Rules of Procedure states as follows:
3. Consolidation of Cases
Where two or more proceedings are pending before the GSB and it appears to
the GSB that,
a. they have a question of law or fact in common;
b. the relief claimed in them arises out of the same transaction or
occurrence or series of transactions or occurrences; or
c. for any other reason an order ought to be made under this rule,
d. the GSB, on such terms as it considers advisable, may abridge the
time for placing a grievance on the hearing list, and may order that:
e. the proceedings be consolidated, or heard at the same time or one
immediately after the other; and/or
f. any of the proceedings be stayed until after the determination of
any other of them.
[16] The Association, on behalf of Chiba, noted that it had agreed to be bound by my
decision in this motion, but without prejudice to its position that Vice Chair Herlich is
seized of the Chiba matters.
[17] It is the Association’s position that Rule 3 does not apply in this instance; that in
any event, I do not have the jurisdiction to direct that these cases be heard together;
and, even if I do have the jurisdiction to do so, I should exercise my discretion not to
direct that they be heard together.
[18] According to the Association, Article 15 of the collective agreement, which
addresses the Dispute Resolution Procedure, is a very robust provision in which the
parties have worked out how disputes will be handled. In particular, AMAPCEO relies
on Article 15.9, the Joint Review Process (“JRP”), for the proposition that the parties
have a process by which they meet regularly in order to streamline dispute resolution,
including “to review all cases referred to arbitration in order to determine whether they
can be resolved, expedited or consolidated” (Art. 15.9.1).
[19] In these two cases, according to the Association, the parties did not discuss
having the Argyropoulos and Chiba matters heard together, even though they would
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each have been aware that there were common elements in some aspects of the two
complainant’s disputes. The Association argues that was the time for the parties to
decide that these matters should be adjudicated together, that the time has now passed
to do so, and the Employer has waived any right to have the matters heard together.
[20] If that opportunity was missed because the Chiba and Argyropoulos matters had
not come to the JRP at the same time, then the Association argues that the Employer
should have raised its concerns when the scheduling of the hearings was being done in
the Joint File Review process with the GSB. Even if the Argyropoulos file came later,
that would have been the time for the Employer to have asserted that it should be joined
to the Chiba matters for hearing. In any event, the Association points out that Vice
Chair Herlich was chosen by the parties to hear the Chiba matters, and their choice
should be honoured as he is now seized of those matters, and further hearing dates
have been scheduled before him in March and April 2017.
[21] The Association relies on the language of Rule 3 to argue that it applies where
two or more proceedings before the Board have not already commenced, but are
“pending”. It further relies on the provision in the Rule that the GSB may abridge the
time for placing a grievance on the hearing list, which AMAPCEO argues contemplates
a grievance that has not already been placed on the hearing list and assigned to a
different adjudicator. In this instance, the Chiba grievances have already been
assigned to Vice Chair Herlich, and the Argyropoulos grievance has been assigned to
me. As such, neither of these disputes is “pending”, nor are they matters that have not
already been placed on the hearing list.
[22] Arguing for Argyropoulos, Ms. Pollock stated that the Association had not thought
that the Employer was contesting this complainant’s allegations of harassment, but
rather the issue was whether the Employer had acted in an appropriate manner in light
of the poisoned work environment to which Chiba is alleged to have contributed. As
such, the Association had not understood that it would have to call evidence to prove
Argyropoulos’ allegations of harassment. That being its understanding, there would be
no need to make findings of fact regarding Chiba’s actions, and would limit the
possibility of inconsistent findings of fact should these matters be heard by different
adjudicators.
[23] Even if the Employer is requiring the calling of evidence, according to
AMAPCEO, it has identified only two matters that may actually be in contention: A
comment Chiba is alleged to have made in October 2014, and an incident that is
alleged to have occurred on April 2, 2015, but which Chiba contends did not happen
(banging on Argyropoulos’ office door).
[24] In the course of the argument it became clear that Argyropoulos is not relying on
an incident of alleged harassment by Chiba in October 2014. Chiba’s counsel had
indicated that Chiba did not recall the incident, so it had appeared that this may have
been one of the areas of disputed evidence. However, since AMAPCEO will not be
relying on this incident in the Argyropoulos case, it seems this is no longer an area of
concern in the calling of evidence. As such, the Association maintains that the overlap
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in facts that may be contentious is insignificant, and hearing these matters together is
therefore not necessary.
[25] Counsel for Argyropoulos argued that the Association would be calling medical
evidence to support Argyropoulos’ claim that he was forced to quit his employment
because of the effect the allegedly toxic workplace was having on his health. This
evidence would be extremely confidential and sensitive, and should not have to be
called in front of Chiba or her representatives when it has nothing to do with her issues
with this Employer.
[26] Counsel for Chiba argued that the first of her disputes regarding a letter of
reprimand has nothing to do with Argyropoulos. Chiba’s suspension was premised on
the alleged harassment of Argyropoulos, but it will be AMAPCEO’s contention in that
instance that the Employer cannot call any evidence. The Association maintains that
management only relied upon a framework that had been provided by the WDHP
investigator: the Employer had not itself done any investigation of its own, and as such
should be precluded from calling any evidence to support its contention that it had just
cause to discipline Chiba.
[27] Since it is the Association’s intention to make many objections to evidence that
the Employer may seek to call in the Chiba case, it is AMAPCEO’s position that should
these matters be heard together it would result in prejudice to Chiba, as I would be
hearing Argyropoulos’ evidence of what Chiba may have said or done to him, but that
should not be evidence that could be relied upon for Chiba’s discipline.
[28] The Association argues that my jurisdiction to hear the Argyropoulos case arises
out of the collective agreement, and while the GSB may have rules, those rules cannot
be inconsistent with the Ontario Labour Relations Act, 1995 (“OLRA”) or the Crown
Employees Collective Bargaining Act (“CECBA”). Thus, it is argued, I cannot take
jurisdiction from another arbitrator who has already been appointed and who is seized
of a different matter, except with the agreement of the parties, which, in this case
AMAPCEO is not giving.
[29] AMAPCEO does not dispute that section 48(12) of the OLRA applies, because
CECBA outlines that it is sections 48(1) to (6) which do not form part of CECBA. It
relies on subsection 50(1)(b) of CECBA for the proposition that the parties agree on the
selection of the Vice Chair who will determine certain matters, and on subsection
50(1.1) for the proposition that the employer and trade union “may make an agreement
as to the sequence in which the Grievance Settlement Board shall consider outstanding
matters in which the employer and trade union have an interest”, and the GSB must
give effect to that agreement. Subsection 50(3) states that either party can give notice
to the GSB that it no longer wants the agreement to apply, and in that case, the GSB
must cease to give effect to such an agreement. In this case the parties have not
agreed on any sequence in which the GSB may consider the Argyropoulos and Chiba
matters, but the Association points out that CECBA anticipates that the parties can
agree on their own process, and that any party can withdraw from that process.
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[30] Subsection 48(12) of the OLRA grants an arbitrator a broad range of powers,
including to make procedural rulings, and to accept oral or written evidence as, in the
arbitrator’s discretion, she or he considers proper.
[31] The Union relied upon the following decisions in making its arguments: Southern
Railway of British Columbia Ltd. v. C.U.PE. Local 7000, 2001 CarswellBC 3359
(Larson); Canadian Union of Public Employees, Local 416 (Toronto Civic Employees
Union) v. Toronto (City) (Job Posting Grievance), [2002] O.L.A.A. No. 755 (T. Joliffe)
(the “Joliffe decision”); Canadian Union of Public Employees, Local 4000 v. Ottawa
Hospital (Scope Decision Grievance), [2004] O.L.A.A. No. 390 (Hornung) (the “Hornung
decision”); Ontario Public Service Employees Union (Moody) and Ministry of Children
and Youth Services, 2012 CanLII 35048 (ON GSB)(Abramsky).
DECISION
[32] Having considered the submissions of the parties, and reviewed the
jurisprudence, for the reasons that follow I am of the view that I do not have the
jurisdiction to order the consolidation of the Chiba and Argyropoulos disputes.
[33] I have been appointed to hear the Argyropoulos dispute, and had already
commenced the hearing on September 13, 2016. At the parties’ request, Vice Chair
Herlich has been appointed to hear the Chiba disputes; he has commenced his
proceeding and has issued a preliminary decision; he has held a day of mediation at the
request of the parties; and has further hearing dates already scheduled for March and
April 2017.
[34] I agree with the Joliffe decision, cited above, in that I do not believe that my
power to make interim orders on procedural matters pursuant to subsection 48(12)(i) of
the OLRA can extend to incorporating into my proceeding matters that are already
properly before another Vice Chair of the Board. The parties here agreed to refer these
matters to different adjudicators, and since both adjudicators have already taken
jurisdiction and participated in their respective processes, in the absence of agreement
of the parties, it is simply too late in all the circumstances of these cases to consolidate
these matters. I do not agree with counsel for the Employer’s characterization of this
motion as simply seeking an evidentiary ruling: the Employer is making a far more
radical request in seeking, over the objection of the Association, to have matters that
are before different adjudicators heard by one of them, thereby ousting the jurisdiction
of the other adjudicator.
[35] In the Hornung decision, cited above, the arbitrator had similarly held that where
the parties had referred grievances to different arbitrators, absent the agreement of the
parties, one arbitrator cannot assume the jurisdiction of another arbitrator or board of
arbitration. Arbitrator Hornung further noted (at para. 35) that he could not cede his
jurisdiction. Even if he had ceded his jurisdiction, he was not certain that the other
board of arbitration would be in a position to take jurisdiction without the parties’
agreement. Arbitrator Hornung stated as follows:
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38. I am satisfied that an arbitrator, properly appointed, hearing similar
grievances, with similar issues, between the same parties, under the same
collective agreement may in fact, pursuant to section 48(12)(i), make a
consolidation order, even in the absence of consent by one of the parties.
However, I am not convinced that I have jurisdiction, even interpreting
section 48(12)(i) broadly, to either assume jurisdiction in order to
incorporate into my proceedings another separately filed grievance – over
which I have not gained jurisdiction by appointment or consent of the
parties – from another arbitrator who has been duly appointed; or,
alternatively, transfer my jurisdiction in the matter to another arbitrator
without such consent.
[36] In the context of the GSB, in McClelland/Ward, cited above, Vice Chair Briggs
addressed a Rule 3 motion made by the employer. In that case Ward’s grievance was
to be heard by Vice Chair Abramsky, and McClelland’s by Vice Chair Briggs.
McClelland’s counsel did not object to the consolidation of the grievances for hearing
before Vice Chair Briggs, but Ward’s counsel did object. It appears from a reading of
para. 19 of the decision that the Ward case had already commenced before Vice Chair
Abramsky, but counsel for Ward did not make the jurisdiction argument that has been
made before me. He did not argue that Vice Chair Briggs was without jurisdiction to
remove a case that had already commenced before another adjudicator who was
seized of that grievance.
[37] McClelland had a termination grievance (which related to an incident that had
involved Ward) as well as other discipline and harassment and discrimination
grievances that pre-dated her termination. In that instance Vice Chair Briggs ordered
that the Ward and McClelland matters be heard together because there were common
questions of fact, and perhaps law, in respect of the termination grievance, and because
it seemed apparent that the relief claimed in that matter arose out of the same
transactions or occurrences (at para. 20). She found that the cases were inextricably
interwoven, and that it would be detrimental to the parties if there were differing findings
of fact regarding the incident of alleged assault. McClelland’s grievances were to
proceed first, and Ward’s grievance alleging workplace violence and the employer’s
failure to protect her, was apparently to be addressed secondarily.
[38] The most significant difference between what appears to have been argued in
McClelland/Ward and before me is that here AMAPCEO asserts that I do not have the
jurisdiction to order that the Argyropoulos and Chiba disputes should be heard together.
That was simply not argued before Vice Chair Briggs, nor does it appear to have been
argued in any other of the GSB decisions the Employer has relied upon.
[39] As well, in McClelland/Ward one of the grievor’s counsel was not objecting to the
matters being heard together. In the case before me, both of the Association’s counsel
for the complainants are vehemently objecting to the matters being heard together.
[40] In Upson, cited above, Vice Chair Harris considered an employer request to
consolidate the hearing of four grievances filed by one grievor, with one grievance filed
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by another grievor. The issue alleged to be common to the grievances was a
November 2011 physical altercation between the two grievors. It is noteworthy that in
that case the employer agreed that one of Upson’s four grievances had nothing to do
with the altercation, and that it was to be scheduled separately in its own right. That is
not the case before me: the Employer here wants all of Chiba’s disputes heard together
with the Argyropoulos matter even though one has nothing whatsoever to do with him.
In any event, in Upson, the Vice Chair held that two of Upson’s other grievances also
had little to do with the altercation itself, and held that they should not be heard with the
other grievor’s matter.
[41] Another distinguishing factor in Upson was that the parties in that case, OPSEU
and the employer, agreed on the general considerations in the application of Rule 3,
and counsel for the two grievors, while unable to agree on consolidation, were prepared
to concede that the matters could be heard together. That is not the case before me:
As outlined earlier, counsel for the two complainants clearly do not concede that these
matters could be heard together. Ultimately, Vice Chair Harris directed that only the two
grievances, those filed by each grievor regarding the same incident, would be heard
together.
[42] What is significant is that there is nothing in the Upson decision to suggest that
any proceedings had begun before any other Vice Chair by the point at which the
motion to have the matters consolidated was made, so unlike the situation here, that
was not a problem that Vice Chair Harris had to consider.
[43] In Moore et al, cited above, Moore had filed 11 grievances, and two other
grievors had filed two grievances each. The latter two grievors’ matters had been
referred to the GSB, but had not yet been scheduled by the time that the employer
made a motion that all of the grievances be heard together. Vice Chair Nairn accepted
that all of the discipline grievances of the three grievors arose out of the same incident
and what had occurred in its aftermath (para. 19), and found that it would not make
sense to hear the evidence three times in separate proceedings (para. 20). This
decision is of little assistance to me in this motion as it is clear that in Moore et al the
two sets of grievances that the employer was seeking to have heard together with the
Moore grievances had not yet been scheduled. As such, no other adjudicator was
seized of the other two sets of matters, and Vice Chair Nairn determined that the Rule 3
considerations had been met.
[44] In this instance, AMAPCEO has made the argument regarding jurisdiction. Once
an argument about jurisdiction has been raised, it is incumbent on the adjudicator to
address it, as it goes to the heart of whether one can hear a case or not. For the
reasons already outlined, in the absence of agreement of the parties, in my view I
cannot take jurisdiction over disputes that are already before another Vice Chair of the
Board, and where that adjudicator is seized of the matters before him.
[45] Even if I am incorrect, and could be said to have jurisdiction to consolidate the
Chiba and Argyropoulos disputes, for reasons that follow, I would not exercise my
discretion to do so.
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[46] In the exercise of an adjudicator’s discretion, Rule 3 contemplates consideration
of whether there is a question of law or fact in common; whether the relief claimed in the
proceedings arises out of the same transaction, or occurrence or series of transactions
or occurrences; or, for any other reason that the Board considers should cause it to
order that matters be consolidated, heard at the same time, one immediately after the
other, or if any of the proceedings should be stayed pending the determination of any
other of the proceedings.
[47] The Argyropoulos dispute appears to be a discrete matter, while the Chiba
disputes are far broader ranging in scope, in that they already include a matter that has
nothing to do with Argyropoulos. Furthermore, it appears the Employer may move to
add a third dispute to the Chiba matters, and while there may allegedly be some aspect
of that case that involves Argyropoulos, even the Employer is not asserting that his role
in that Chiba case would be central to his issues before me.
[48] In light of the parties’ submissions, it appears to me that there is not likely to be
much overlap in the evidence between the two proceedings. There may be one aspect
of Argyropoulos’ dispute that would overlap with Chiba’s disputes, so there may be a
limited question of fact that the disputes have in common.
[49] The relief that Argyropoulos is seeking in his dispute arises in part from the same
occurrences that are at the heart of one of Chiba’s disputes, but as already noted, it
appears that only one aspect of Argyropoulos’ allegations in his dispute is actually being
challenged by Chiba. As such, there is some, but apparently very limited, overlap
between the occurrences for which each complainant is seeking relief.
[50] Overlapping facts are not the only consideration when weighing whether cases
should be heard together: there is also the question of the use of resources and
whether one party may be prejudiced in a joint process. In this instance, given that
there appears to be limited overlap in the facts in dispute, it would be unfair to
Argyropoulos and the Association to require that complainant and his counsel to have to
sit through days of hearing that have nothing whatsoever to do with his dispute.
[51] In addition to the unnecessary costs associated with having counsel for
Argyropoulos present, there is a strong likelihood that there would be considerable
delay in the resolution of the Argyropoulos dispute. This is because the Chiba
reprimand dispute must precede her three day suspension dispute, as the latter
disciplinary response is premised on her already having received a written reprimand.
Thus, the Argyropoulos dispute, and any evidence relating to it, would likely be left in
limbo until the Chiba three-day suspension dispute could be addressed.
[52] The issue that purportedly led to Argyropoulos quitting his employment was his
inability to continue to work with Chiba, in an environment that his medical advisor
apparently felt was bad for his health. If that position is maintained, and the Association
intends to call medical evidence in this regard, then I agree with counsel for
Argyropoulos that it would be an unnecessary breach of confidentiality to have Chiba
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and her counsel present for such evidence as Argyropoulos’ medical history has nothing
to do with her disputes. In the normal course, this is something that could be addressed
through procedural rulings in the course of a hearing so that a complainant’s medical
privacy could be maintained. However, where there are so few good reasons to hear
these matters together, this is simply another reason not to hear the Chiba and
Argyropoulos matters together.
[53] For all of the above reasons, and even if I am incorrect about whether I have the
jurisdiction to hear the Chiba matters with the Argyropoulos dispute that is already
before me, in the exercise of my discretion I would decline to direct that these matters
be heard together.
[54] While it is not necessary to address every one of the Association’s many
arguments in light of my ruling, I do not want to leave unaddressed the argument made
regarding the Employer’s alleged waiver of the consolidation issue during the Joint File
Review process. The Association argued that because the Employer had not raised
during the Joint File Review process, or earlier, that the Argyropoulos dispute should be
heard with the Chiba disputes, that it should be found to have waived its right to do so.
[55] In Moore et al, cited above, Vice Chair Nairn addressed a union’s argument that
in the Joint File Review process the employer had had the opportunity to raise with the
union whether three grievors’ disciplinary grievances should be heard together because
they arose out of the same circumstances. Having failed to do so, the union argued that
the employer could not raise it later. At para. 21 of the decision, Vice Chair Nairn
stated:
21. Joint File Review is an administrative process whereby representatives of
the parties meet with the Board for purposes of scheduling hearings. It cannot
be taken as producing an agreement between the parties with respect to matters
of procedure that are unalterable by the Board in the course of a hearing, should
circumstances warrant.
[56] I agree with Vice Chair Nairn’s comments in this regard, and cannot accept
AMAPCEO’s argument that just because parties may not have turned their minds to
procedural matters during the Joint File Review process, that that means a party cannot
make a procedural motion before the Board in the course of a hearing. The GSB is the
master of its own proceedings; the GSB Rules of Procedure envision that there may be
matters that must be decided in the course of a proceeding; and, section 48(12) of the
OLRA, to the extent that it is applicable to a matter before the GSB, also grants the
Board broad powers in the conduct of a hearing. As such, in this instance I cannot find
that the Employer should have been precluded from make this motion at this stage of
the proceeding simply because it had not raised the matter during the Joint File Review
process.
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[57] In conclusion, for the reasons outlined above, the Employer’s motion is hereby
denied. I remain seized of the Argyropoulos dispute, and refer the matter to the
Registrar to set further hearing dates in consultation with the parties.
Dated at Toronto, Ontario this 4th day of January 2017.
Gail Misra, Vice Chair