HomeMy WebLinkAboutP-2015-2081.Huppmann.17-02-01 Decision
Public Service
Grievance Board
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Commission des
griefs de la fonction
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Toronto (Ontario) M5G 1Z8
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PSGB#2015-2081
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Huppmann Complainant
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The Crown in Right of Ontario
(Ministry of Community Safety and Correctional Services) Employer
BEFORE Marilyn A. Nairn Vice Chair
FOR THE
COMPLAINANT
Richard Huppmann
FOR THE EMPLOYER Peter Dailleboust
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING January 16, 2017
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Decision
[1] By decision dated April 14, 2016 the Board made a finding that the complainant
had been required to be on call during vacation periods and was therefore entitled to on
call pay pursuant to section 21 of the Compensation Directive (the “Directive”). The
claim was remitted to the parties for purposes of calculating the amount owing. The
parties were unable to reach agreement with respect to the remedy. The hearing
reconvened on January 16, 2017 and this decision deals with that issue.
[2] The complainant seeks payment for certain vacation days, regularly scheduled
days off (“RDOs”), lieu days, compensating days, and statutory holidays taken
throughout 2015. There was no dispute as to the characterization of the days claimed or
the number of hours of on call each of those days would represent.
[3] However, the employer raised two issues with respect to the scope of the claim.
First, it argued that the Board had no jurisdiction to provide a remedy earlier than 14
days immediately preceding the giving of the notice of proposal to file a complaint.
Second, while it agreed that vacation periods included lieu days and compensating time
off, it argued they did not include RDOs or statutory holidays.
The jurisdictional issue
[4] As the complainant gave timely notice of proposal to file his complaint and filed a
timely complaint to the Board, there was no issue taken at the April 2016 hearing as to
the Board’s jurisdiction to hear and determine the merits of the application. The scope of
the Board’s remedial authority has, however, now been raised.
[5] The notice of proposal to file a complaint was given to the appropriate Deputy
Minister on August 27, 2015. It is the position of the employer that the remedial claim
can only start as of August 13, 2015, 14 days prior to the giving of that notice. The
employer argued that, as the Board has no jurisdiction to extend time limits under
Ontario Regulation 378/07 (the “Regulation”), it also has no jurisdiction to remedy the
breach of a working condition or term of employment that occurred more than 14 days
before the giving of the notice of proposal to file a complaint. To find otherwise, argued
the employer, would render the mandatory time limits under the Regulation irrelevant.
[6] The employer argued that the one exception to this limitation arises where the
claim is made under the Human Rights Code, wherein the Board has jurisdiction to
interpret and apply that legislation as applicable to excluded employees. However in this
case, it argued, the claim was simply with respect to a breach of a term of employment
in the Directive.
[7] The employer acknowledged that the claim (subject to the second issue raised)
properly continued until January 9, 2016.
[8] The complainant argued that he did not analyse the information he was being
given; that he trusted the employer to be fair and therefore ought not to be held to a
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strict time limit. It was, he asserted, only after a realization that he and others would
have to hold the employer to account that the complaint was filed.
[9] Does the Board have jurisdiction to provide a retrospective remedy beyond the
14 days prior to the giving of notice of proposal to file a complaint? The employer relied
on the language of the Regulation and the Board’s decisions in and since St. Amant v.
Ontario (Ministry of Community Safety and Correctional Services), 2013 CanLII 4673.
[10] In that case, and in a number of subsequent cases (see for example, Hauth v.
Ontario (Ministry of Community Safety and Correctional Services), 2013 CanLII 74165
and Hasted v. Ontario (Community Safety and Correctional Services), 2016 CanLII
7473, and the cases cited therein) the Board has concluded that the time limits for the
giving of the notice of proposal to file a complaint are mandatory and that the Board has
no discretion to relieve against those time limits.
[11] Thus, where the giving of the notice of proposal to file a complaint is untimely,
the Board has no jurisdiction and is precluded from entertaining the merits of a
complaint. Does that limitation also speak to the Board’s ability to grant a remedy in
other circumstances?
[12] The notice of proposal to file this complaint was given on August 27, 2015. Had
the complainant given notice of proposal to file a complaint earlier, there is no doubt that
the Board would have had the jurisdiction to consider that broader complaint and what
remedy might flow from that earlier point in time. This is arguably a continuing grievance
as the employer’s requirement that Sergeants remain reasonably available to be
recalled to work during vacation periods extended into January 2016, even though any
alleged violation is specific to each vacation period taken. As noted earlier, the
employer took no issue with any claim following the giving of the notice of proposal.
[13] At the April 2016 hearing, the complainant entered into evidence an earlier May
21, 2015 email that advised that he was required to leave a phone number where he
could be reached during vacation periods. As noted in paragraph 35 of the April 14,
2016 decision, that email is less clear with respect to whether it authorized on call as it
did not expressly stipulate that the Sergeants were required to remain reasonably
available for recall to work. As already indicated however, had the complainant given
notice of proposal to file a complaint immediately following the May 21, 2015 email,
claiming on call pay for subsequent vacation periods, that time period would properly be
included in the complaint and in any remedial framework.
[14] However, had the complainant given notice of proposal to file a complaint on
August 27, 2015, simply claiming on call pay for one vacation period taken immediately
following the employer’s email of May 21, 2015, that complaint would have been
untimely, absent some evidence warranting a conclusion that the crystallizing of the
issue occurred later. In order for the Board to have jurisdiction to consider such a
complaint, the circumstances giving rise to the complaint must have occurred within the
14 days immediately prior to the giving of notice. Alternately put, if the circumstances
giving rise to that complaint arose on, say, June 1, 2015, notice of proposal to file a
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complaint would have been required no later than June 15, 2015 in order for the Board
to have jurisdiction to entertain the complaint and order any remedy.
[15] The continuing nature of the complaint only assists the complainant with respect
to claims occurring after the giving of notice of proposal to file a complaint. The
complainant cannot achieve indirectly what he cannot achieve directly. If the Board has
no jurisdiction to even entertain a complaint with respect to an earlier time period, I am
hard pressed to determine on what basis the Board could, in effect, reach back from a
later, timely complaint in order to remedy that earlier time period. While the Board has
jurisdiction to entertain a complaint alleging a continuing violation, notwithstanding that it
is not filed from the date of the first occurrence of an alleged breach, the remedy may
still be limited and regard must be had in that context to the time limits involved for
bringing the complaint.
[16] I have no evidence that the employer made any representation regarding any
entitlement to, or possible payment for on call pay that would warrant the complainant
holding off from making a claim. The complainant did not assert that he was unaware
that he was entitled to on call pay. Rather, he asserted in his Form 1 that he became
aware that he was being required to be on call when he received the email dated
August 27, 2015, “which used the same language contained within…section 21(2)” of
the Directive. That is, the complainant became aware of the circumstances giving rise to
his complaint on August 27, 2015. He gave his notice of proposal to file a complaint that
same day. His primary concern to that point had been the fact that the employer was
delaying the approval of vacation requests, the other matter raised in his complaint.
[17] In these circumstances therefore, I find that the remedial claim in this case is
limited to 14 days prior to the date of giving notice of proposal to file the complaint, that
is, August 13, 2015.
[18] I do have concerns about a lack of clarity from the employer with respect to
communicating a requirement that Sergeants be reasonably available for recall to work.
Absent a clearly expressed requirement and corresponding compensation, the
employer must accept that Sergeants are under no obligation to remain reasonably
available to be recalled to work during a period that is not their regularly scheduled work
period. The employer cannot simply rely on the professionalism of its Sergeants to
require that they remain on call because the employer might need them during periods
when they are not otherwise scheduled to work.
What does ‘vacation period’ include?
[19] While the employer agreed that lieu days and compensating time off should be
treated as falling with a vacation period for purposes of on call pay, it did not agree that
RDOs or statutory holidays should be so included. It referred to paragraph 30 of the
Board’s original decision in this case, arguing that the on call requirement was found to
be limited to vacation periods and the question was simply what on call hours properly
fell within a vacation period.
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[20] The complainant argued that vacation periods could refer to longer periods than
while on vacation as, he argued, the emails covered the entire period, not just vacation.
He argued that he did not have to be travelling to be on vacation and that vacation
ought to be given its normal meaning of a period of suspension from work used for
holiday. The complainant argued that the emails stated that he could be called back to
work at any time while on vacation, not just on days credited as vacation.
[21] Section 21 of the Compensation Directive provides for on call pay when an
employee:
…keeps himself or herself reasonably available for recall to work during a period
(authorized by his or her supervisor) that is not his or her regularly scheduled work
period…
[22] The language used by the employer in requiring the complainant to be
reasonably available, and thereby authorizing the on call, stated:
...managers who are on vacation may be called back…at any time; therefore they
are required to provide a telephone number at which they can be reached during
this period.
[23] The complainant is entitled to be compensated for periods of on call during his
vacation periods. There is no dispute that that includes time spent on call during any
day for which a vacation credit, a lieu day, or a compensating day was taken.
[24] I am further satisfied that the ‘vacation period’ ought to be liberally construed so
as to reflect those stretches of consecutive days where the employee is absent from
work and during which period he utilizes a vacation credit, lieu day, or compensating
day off. All of those are earned benefits that entitle an employee to be absent from work
during periods they might otherwise be scheduled for work.
[25] The employer may rely on an assumption that for RDOs or statutory holidays, a
Sergeant (or a sufficient number of Sergeants) may be reasonably available to be
recalled to work without requiring them to be so. That assumption changes for stretches
of booked vacation when it is understood that Sergeants may absent themselves from
home and for longer periods. Those assumptions, however, do not take account of the
myriad of circumstances in between.
[26] It is generally understood by both employers and employees that RDOs and
statutory holidays are often used to extend vacation periods without the need to utilize a
vacation or other credit. According to the Directive, on call is payable for periods that
are not regularly scheduled work periods. On its face, that includes RDOs and statutory
holidays not worked. A limitation arises in this case as the employer required the
complainant to be on call only during ‘vacation periods’. At the same time, that
requirement was a ‘blanket’ direction to Sergeants. It was ambiguous and failed to
provide direction responsive to individual circumstances, potentially leaving Sergeants
to err on the side of caution by remaining reasonably available for recall to work for a
broader period than the employer actually intended or required. Where they are
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contiguous to vacation, lieu, or compensating days, I therefore find it appropriate to
include RDOs and statutory holidays as part of the vacation period.
[27] I hereby find that, for purpose of this claim, where an RDO, or consecutive RDOs
or statutory holidays abut a vacation day, lieu day, or compensating day, they are
properly treated as falling within a vacation period for which the employer required the
complainant to be on call. Therefore, and having regard to the limitation on the scope of
the remedy expressed at paragraph 17 above, on call hours payable during the relevant
period of this claim are as follows:
August 13 – vacation – 16 hours
August 14 – vacation – 16 hours
August 15 – RDO – 24 hours
August 16 – RDO – 24 hours
August 21 – vacation -16 hours
August 22 – RDO – 24 hours
August 23 – RDO – 24 hours
September 14 – compensating time – 16 hours
October 5 – lieu time - 16 hours
October 9 – vacation – 16 hours
October 10 – RDO – 24 hours
October 11 – RDO – 24 hours
December 25 – statutory holiday – 12 hours
December 26 – statutory holiday – 12 hours
December 27 – vacation – 12 hours
December 28 – RDO – 24 hours
December 29 – RDO – 24 hours
Total: 324 hours
[28] Section 21(1) of the Compensation Directive sets on call pay for a Schedule 5
manager such as the complainant at $1.00 per hour. I hereby direct the employer to
forthwith pay to the complainant the sum of $324.00 less required deductions. I will
remain seized with respect to the implementation of this award.
Dated at Toronto, Ontario this 1st day of February 2017.
Marilyn A. Nairn, Vice Chair