HomeMy WebLinkAbout1993-1102.Murphy.94-03-02
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~ ONTARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
II- GRIEVANCE COMMISSION DE
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SETTLEMENT REGLEMENT
BOARD Des GRIEFS
180 DUNDAS STREET WEST SUITE 2100, TORONTO, ONTARIO, M5G lZ8 TELEPHONE/TELEPHONE (4 6) 326-1388
180, flUE DUNDAS OUEST BUREAU 2100 TORONTO (ONTAFlIO) M5G lZ8 FACSIMILE'TELECOPIE (416) 326- r 396
1102/93
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Murphy)
Grievor
- and -
The Crown in Right of ontario
(Ministry of Correctional Services)
Employer
BEFORE N. Dissanayake Vice-Chairperson
FOR THE G Adams
GRIEVOR Grievance Officer
Ontario Public service Employees Union
FOR THE B Ross
EMPLOYER Grievance Administration Officer
Ministry of Correctional services
HEARING February 28, 1994
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DECISION
This matter was heard pursuant to the expedited
arbitration procedure contained in the collective agrement
between the parties.
Since July 1988 the grievor Ms Brenda Murphy has been
employed in the Laundry Dept. of the Mimico Correctional
Centre in the classification of Industrial Officer One. At
least since then the consistent practice of the employer has
been to schedule only correctional officers to work on
statutory holidays Other employees including Industrial
Officers received a paid statutory holiday on the designated
statutory holidays It is common ground that on statutory
holidays correctional officers worked in the laundry, while
the grievor was scheduled off In her grievance dated March
5, 1993 the grievor claims that since 1988 she has been denied
the opportunity to earn premium pay by working on statutory
holidays, while the employer has used correctional officers to
backfill her jOb on those days The union does not dispute
the long line of GSB cases that have held that employees have
no right under the collective agreement to work on statutory
holidays The union acknowledges that it is an exclusive
management function of the employer to determine which
employees will work on a statutory holiday However, the
union takes the position that the exercise of management
rights is fettered by a duty to act in good faith. The crux
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of the union's case is that in denying Ms Murphy the
opportunity to' work on statutory holidays, th~employer acted
,
unreasonably and in bad faith The union seeks compensation
for each statutory holiday since July 1988 on which the
grievor was treated in this manner.
The employer made a preliminary motion that the grievance
was. untimely and not properly before the Board On the
merits, the employer denied that there was any bad faith It
was submitted that the practice of scheduling only
correctional officers is a long standing one which has been
consistently followed, and that the practice was follo't<led
pursuant legitimate operational reasons
The evidence of Ms Murphy was that she was always aware
that she was scheduled off on statutory holidays and that
correctional officers worked in the laundry while she was off
However, her uncontradicted testimony is that until late
February 1993 she was not aware that she may have recourse
against this situation under the collective agreement At
that time, one of her co-workers grieved the same
circumstances, and through conversation with him, Ms Murphy
became aware of the right to grieve In Re Veronica Pierre,
unreported endorsement of the Divisional Court dated July 11,
1990, O'Leary J stated at p. 2 that " it is only the
subjective awareness of the employee that she has a complaint
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arising out of a possible violation of the agreement tpat sets
the 20 day time limit running" It is cle~r on the evidence
before me that Ms Murphy did not obtain that "subjective
awareness" until late in February 1993 Therefore, the
employer's preliminary motion fails and this grievance is
arbitrable
Turning next to the merits of the grievance, the union is
correct in its claim that the employer must be held to a
standard of good faith in the exercise of its exclusive
management functions See, Re Bousquet, 541/90 (Gorsky) and
Re Lumley, 1257/91 (Gorsky). The onus is on the union to
substantiate its allegation that the employer has acted in bad
faith.
Bad faith may be demonstrated if there is evidence that
the employer acted out of personal malice towards the grievor.
There can be no such allegation here since the evidence is
that Ms Murphy was treated in the same way as all other non
correctional officer staff pursuant to a longstanding policy
Also, if the union is successful in establishing that the
employer "was pursuing some other goal under the guise of
exercising an exclusive management function, then it could not
be said to be exercising the function in good faith" (Re
Bousquet, supra, at p 24)
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The union's claim was that the employer's action was
unreasonable and in bad faith In Re Bousquet (supra) at pp
59-61 the Board observed as follows about the relationship
between unreasonableness and bad faith
Bona fides may have a broad or narrow meaning
depending on the context See, Manon Schiralian,
914/86 (Roberts), referred to in Shaw, 410/88
(Watters), where the Board stated, at p 6
"Reasonableness in this context is a species of
good faith" The Shaw case was concerned with a
grievance which asked the Board to find that a
purported release of a probationary employee under
the authority of section 22(5) of the Public
Service Act for ostensibly having failed to ~eet
"the requirements of his position amounted to a
dismissal without just cause which the Board had
jurisdiction to deal with under s. 18(2) (c) of the
Act In an earlier case decided by the Board,
Leslie (1978), 22 LAC. (2d) 126 (Adams), at p.
134, the majority of the Board stated
.. this Board is of the opinion that the
employer cannot camouflage either the
discipline or the termination of an
employee for a reason other than the
employee's failure to meet the
requirements of his position.. by the
guise of a 'release' under the Publ ic
Service Act. This Board therefore, has
jurisdiction to review a contested
release to insure that is what it
purports to be. But in the adjudication
of such a grievance, this board is
without jurisdiction to evaluate and
weigh the reasons of the employer unless
the Collective Agreement provides
otherwise. The Board must only be
satisfied that the employer, in good
faith, released the employee for a
failure to meet the requirements of his
position As long as the Board can be
satisfied that the employer has made an
evaluation of that kind, it has no
jurisdiction to review the fairness of
correctness of that termination under
[what is now s. 18(2) (c) of the Act]
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In commenting on the use of th~ term
"unreasonable", in some earlier decisions of the
Board dealing with the good faith exercise of the
statutory right to "release" a probationary
employee, the Board stated in Shaw, at pp 5-6
While this term (unreasonable) is
utilized in the earlier decisions we do
not take it to mean that we can review
the merits of the employee's job
performance and reinstate him if we find
that assessment was "unreasonable" that
the employee had not met the job
requirements Reasonableness in this
context is a species of good faith
Whereas the phrase "bad faith" could
encompass a release improperly motivated
or maliciously intended,
"unreasonableness" speaks more to an
objective assessment that the release did
not flow logically or rationally from the
facts If, for example, there was simply
no evidence that a probationary employee
had not fulfilled or could not fulfil the
jOb requirements, then no matter how well
meaning were the actions of his
superiors, the release would have been
unreasonable exercise of authority
.
The Board in Shaw also dealt with the fairness
requirement that there be a rational relationship
between the facts and the release (at p 6) . This
factor was found to be "nearly synonymous with
'reasonableness'. II In holding that ( ibid. ) the
release can be reviewed as a discharge if the
employer's "assessment that a certain set of facts
justifies release is 'irrational' on any half-
inteiligent view of the matter," the Board
cautioned (ibid. ) that the rational relationship
test should not be placed too high, as
It is easy to brand as II irrational" any
thought process or decision with which
one does not agree The Deputy Minister
must be free to make decisions, without
being found to have acted irrationally
merely because a board of arbitration
might have come to a different decision.
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That is, the test of good faith, in this
context is not one of correctness
The evidence indicates that under the practice of the
employer only correctional officers who were already scheduled
to work on the statutory holiday were used to 'work in the
laundry No correctional officers who were otherwise
scheduled to be off were recalled to perform duties in the
laundry The work the correctional officers performed in the
laundry primarily was the supervision of inmates who worked in
the laundry Undoubtedly in so doing, they performed similar
functions as those the industrial officers would have normally
performed However, there was not a sing~e duty wh~ch they
performed which could be said to be outside their
classification or job descr iption The fact is that in a
correctional institute there is a significant overlap of
duties, such as security and safety, among different
classifications The evidence does not establish that the
correctional officers backfilled the grievor's position on
statutory holidays They did not perform all of the duties
she did as an Industrial Officer, and did significantly less
of it More importantly every duty they performed was within
their own job classification and position specification.
The employer's uncontradicted evidence is that it
followed the practice in question as a means of cost saving
Whether the Board thinks that that goal will be achieved
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through the practice or not, it is a legitimate operational
objective The facts, ~n other words, do not show that the
employer's practice was irrational in the sense described by
the Board in Re Shaw and Re Bousouet
In the result, I find that the evidence does not
establish that the employer exercised its management rights in
bad faith The grievance is therefore dismissed
Dated this 7th day of March, 1994 at Hamilton, ontario
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Nirnal V. Dissanayake
Vice-Chairpersqn
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