HomeMy WebLinkAbout1994-1942.Union Grievance.02-02-20 Decision
~ ~ ~ ONTARIO EMPWYEs DE LA COURONNE
~! ~<O;~~::~E ~;o::~SSION DE
IDIlIIllIa. ~..oIImII1lIlI SETTLEMENT REGLEMENT
'lIl~'" BOARD DES GRIEFS
Ontano
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GSB#1942/94, 0952/00
UNION#MOH-U978, 99U025
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Union Grievance)
Grievor
-and-
The Crown In Right of Ontario
(Ministry of Health and Long-Term Care)
Employer
BEFORE Barry B Fisher Vice-Chair
FOR THE GRIEVOR Richard Blair
Counsel
Ryder Wright Blair & Doyle
Barnsters & Solicitors
FOR THE EMPLOYER Mary Pat Moore and Stephen Patterson
Legal Services Branch
Management Board Secretariat
HEARING July 11, October 18 and November 13, 2001
2
INTERIM AWARD
IntroductIOn
ThIS InterIm Award IS In respect to a number of legal Issues
that arose In a serIes of grIevances In whIch OPSEU has alleged
that the MInIstry has faIled to follow the CollectIve Agreement In
that It has Improperly staffed the MInIstry by USIng a number of
staffing methods, namely, fee for serVIce IndIvIduals, agency
employees, transfer payment employees and unclassIfied staff.
In order to get a handle on the depth of the grIevance, the
partIes negotIated a comprehensIve protocol on InformatIOn
gatherIng, all of whIch was Incorporated Into a Board order dated
May 7, 2001 ThIS order set out In great detaIl the InformatIOn to
be collected, the order of the InqUIry and the questIOns to be
asked
Then at the hearIng on July 11, 2001 the partIes adVIsed me
that before we could proceed WIth the ImplementatIOn of the May
7th protocol, they wanted an award dealIng WIth the Issue as to
whether or not the MInIstry had the rIght to use agency staff to do
bargaInIng unIt work That questIOn IS the subJect matter of thIS
grIevance The term "agency staff refers to IndIVIduals who are
employed by a prIvate enterprIse staffing agency who perform
work for the MInIstry at MInIstry locatIOns alongsIde MInIstry
em ployees
Tnllum Drug Program
It was agreed that the legal Issues would be presented
WIthIn the factual context of how the TrIllum Drug Program
operates
3
The Issues to be decIded were twofold
1 The first Issue IS whether or not the agency employees
were performIng work that IS normally performed by
bargaInIng unIt members
2 The second Issue IS, If I find that the answer to
QuestIOn #lIS "Yes", can the MInIstry legally have thIS
bargaInIng unIt work done by agency employees?
Are agency employees In the TrIlhum Drug Program performIng
work that IS normally performed by bargaInIng unIt employees?
The only wItness called was Mr Carl Marshall, who IS
presently the AssocIate DIrector of the Drug Programs Branch and
prIOr to that he was the ActIng DIrector of the Tnlhum Drug
Program He has been wIth the MInIstry over 20 years
The Tnllum Drug Program provIdes for the dIrect payment
of prescnptIOn drugs for certaIn people that do not have full
Insurance coverage and whose drug costs In rela tIon to theIr
Income entItles them to coverage Apphcants not only apply
InItIally but also must renew theIr apphcatIOns every year Most
apphcatIOns are sent In by mall As the program year IS August 1st
to July 31st, the renewal apphcatIOns are sent out In Apnl and
receIved back untIl about September InItIal applIcatIOns come In
all year round ThIs means that there IS a predIctable seasonalIty
to the staffing requIrements, In that from about Apnl to
September 9 (In other words for about half the year) there IS a
greater demand for both FIle & Mall Clerks as well as for IPCPC,
who process the applIcatIOns and renewals
Agency staff IS used In two posItIOns, Mall & FIle Clerk and
IPCSC (InformatIOn ProcessIng and Customer ServIce Clerk)
Although more of these posItIOns are used dunng the busy season,
the Program uses agency employees In both posItIOns throughout
4
the year AccordIng to Mr Marshall, there has never been a tIme
w hen the Program has not used agency employees for both
posItIOns There are also classIfied and unclassIfied IPCSC
posItIOns All the Mall & FIle Clerk posItIOns are staffed by agency
employees, however It IS admItted that the posItIOn of FIle & Mall
Clerk IS a posItIOn wIthIn the OPS routInely staffed by both
classIfied and unclassIfied staff.
In other words thIS Program routInely uses agency
employees to staff ItS core staffing needs as well as It predIctable
seasonal needs
The MInIstry IS not claImIng that there IS any economIc
advantage to uSIng agency employees Rather the only reasons
gIven as to why the Program uses agency employees over
bargaInIng unIt employees IS as follows
1 The Program IS lImIted In the number of classIfied and
unclassIfied posItIOns that are funded under the
" Staffing" lIne In theIr budget However staffing
through agencIes does not show up on the Staffing lIne,
as It shows up on the "Other DIrect OperatIng
Expenses" ("ODOE") lIne To move money from the
ODOE lIne to the Staffing lIne requIres MBS approval
In other words, thIS reason has nothIng whatsoever to
do wIth actual cost to the MInIstry, rather It has to
solely wIth the budgetIng process
2 There have been dIscussIOns about changIng the way In
whIch the Program would delIver ItS servIces, whIch
may affect the number of FIle and Mall Clerk and
IPCSC posItIOns requIred as the whole mall functIOn
could be outsourced However thIS dIscussIOn has been
gOIng on for a faIr perIod of tIme and nothIng has been
decIded to date
In essence there IS no dIfference at all between the work
beIng performed by bargaInIng unIt members and agency staff.
5
Based on thIS eVIdence there IS no doubt In my mInd that the
agency staff In the Program are performIng bargaInIng unIt work
on a regular and/or seasonal basIs
Is the MInIstry entItled to have bargaInIng unIt work performed
on a regular or seasonal basIs by agency employees?
There IS no dIspute between the partIes that the agency
employees are not Crown employees and that the GSB has no
JUrISdIctIOn to declare such a person an employee of the Crown, so
as to brIng them wIthIn the collectIve agreement ThIs IS a result
largely of sectIOns 1, 8 1(3) and 8 1(10) of the PublIc ServIce Act,
whIch read as follows
Section 1 Crown employee means a person who is,
(a) employed in the serVice of the Crown
Section 8 1 (3) An individual who is employed in the serVice
of the Crown is not considered to be a Crown employee
unless the individual has been expressly appOinted as such
by the Lieutenant Governor in Council, the Commission or
the Minister
Section 8 1 (J 0) In the absence of an express appOintment of
an individual as a CiVil servant, public servant or Crown
employee, the individuals appOintment shall not be inferred
solely from the Circumstances of hiS or her employment
In recognItIon of that statutory framework, OPSEU IS
seekIng a remedy whIch would requIre the employer to post those
posItIOns whIch represent classIfied posItIOns and requIre the
MInIstry to cease and desIst uSIng agency employees for those
posItIOns whIch should be staffed by unclassIfied seasonal
employees The UnIOn's posItIOn IS that thIS award does not need
to cover those employees truly performIng temporary work, as the
eVIdence before me IS that none of the work performed by the
agency employees IS of a temporary or unexpected nature
6
There IS no express prohIbItIon In the CollectIve Agreement
for "contractIng In", that IS uSIng non bargaInIng unIt employees
or non employees to perform bargaInIng unIt work However the
UnIOn submIts that there IS already a GSB decIsIOn that stands
for the proposItIOn that there IS an ImplIed restrIctIOn In thIS
collectIve agreement agaInst contractIng In ThIS IS the decIsIOn of
RIchard Brown In OPSEU (Pilon) and Ministry of Comm unity and
Social Services and AMAPCEO, #1254/99 et al a decIsIOn released
November 5th, 2001
ThIs case Involved the Issue of whether or not the MInIstry
Improperly surplussed certaIn employees when the work was
transferred to non bargaInIng unIt employees of the Crown. VIce
ChaIr Brown, on page 20 of the award says as follows
Based upon the numerous awards cited by Brown and
Beatty, I have no hesitation in concluding that the collective
agreement at hand contains an implied restriction on the
performance of bargaining unit work by all employees outside the
bargaining unit, regardless of whether they ha ve managerial
responsibilities
The MInIstry says that the Pilon case only relates to the
Issue of uSIng non bargaInIng unIt Crown employees to do OPSEU
work, whIch IS not the case before me as here we have non Crown
employees dOIng bargaInIng unIt work
I agree that the Issue raIsed In the Pilon case IS dIfferent,
however the real Issue IS whether the lOgIC and ratIOnale that
lImIts thIS employer from uSIng Crown employees to perform
bargaInIng unIt work should also not apply to lImIt thIS employer
from uSIng non Crown employees from dOIng bargaInIng unIt
work The labour relatIOns ratIOnale behInd thIS rule IS that
wIthout such an 1m plIed restrIctIOn, the em ployer could
undermIne the unIOn's collectIve agreement rIghts by assIgnIng
most or all of the work performed by ItS members to other
em ployees The same labour relatIOns mIschIef can also be
7
achIeved through the process of uSIng agency employees to
perform bargaInIng unIt work TakIng the MInIstry's argument to
ItS natural extreme, the MInIstry, Indeed the entIre ProvIncIal
Government, could staff most or all of ItS OPSEU Job functIOns
through the use of prIvate sector staffing agencIes
The MInIstry also argued that the eVIdence shows that the
Program has a long hIstory of uSIng agency employees to do
bargaInIng unIt work, In fact as far back as 1995 when the
Program started ThIs IS true, but what IS also true IS that one of
the two grIevances beIng heard by me In thIS proceedIng IS
GSB#1942/94, whIch tells me that the UnIOn filed a grIevance over
the MInIstry's staffing practIces even before the Program was
started Therefore, throughout the entIre lIfe of thIS Program, the
MInIstry must be taken to have known that ItS staffing practIce of
uSIng agency employees to do OPSEU work was under attack One
cannot rely on a past practIce when that practIce has always been
the subJect of an unresolved grIevance
The MInIstry argues that OPSEU IS trYIng to do IndIrectly
what It cannot do dIrectly, that IS have the GSB make these
agency employees become Crown employees It may well be that
the net effect of an award In favour of the UnIOn would force the
MInIstry to change ItS staffing procedure, however I am requIred
to Interpret and apply the language In the collectIve agreement
and the relevant statutes as they presently eXIst and determIne
the proper InterpretatIOn The fact that I may find that the
eXIstIng language In the PublIc ServIce Act and the collectIve
agreement does not prevent me from grantIng the remedy
requested In no way prevents the employer from eIther trYIng to
negotIate a change at the bargaInIng table or, as It has does In the
past when faced wIth GSB awards that It strongly dIsagrees wIth,
use ItS legIslatIve power to amend the statutory framework so as
to allow the government to staff ItS workforce In an unfettered
manner by uSIng prIvate agency employees to staff permanent and
seasonal posItIOns
8
I note that the MInIstry In theIr argument refers to the
persons In questIOn as " Temps", thereby ImplYIng that thIS case IS
about whether or not the MInIstry can use non Crown employees
to staff truly temporary posItIOns As I have saId before, that IS
not the case before me as the eVIdence shows that all the posItIOns
In questIOn would be eIther seasonal unclassIfied or classIfied
employment If the persons performIng that Job were Crown
em ployees
Is there any statutory language whIch would prevent me
from orderIng the remedy requested?
In my opInIOn the sectIOns of the PublIc ServIce Act cIted
above only prevent the GSB from transformIng the status of an
IndIvIdual employed In the serVIce of the Crown, but In no way
affects my JUrISdIctIOn to determIne whether the work performed
by that IndIVIdual IS covered by the collectIve agreement
Therefore I find that there IS no express statutory lImItatIOn
upon my power to award the remedy requested
The MInIstry also raIses an argument flowIng from the
UnIOn recognItIon clause In ArtIcle 1 of the collectIve agreement
The relevant prOVISIOns are as follows
11 The Ontario Public Service Employees Union (OPSEW
for the purpose of thiS Central Collective Agreement is
recognized as the exclusive bargaining agent for a
bargaining unit consisting of all employees contained
within the following bargaining units
1 2 For greater certainty, such employees include classified
and unclassified employees, students, GO Temps, and
such other employees as may be mutually agreed
The MInIstry's argument IS that by lIstIng exactly those
types of employees covered In ArtIcle 1 2 and by provIdIng that
other employee groups could be expressly added to the lIst by
9
mutual agreement, thIS shows that the partIes understood that
there were persons performIng OPSEU work who were not
Included In the collectIve agreement SInce all the partIes knew
that the MInIstrIeS used agency employees, It must be that they
Intended to exclude the work performed by these IndIvIduals
unless otherwIse agreed to As such, the partIes have not
negotIated an "eIther/or" recognItIon clause, as In most collectIve
agreements In the prIvate sector
The UnIOn's response IS that all that ArtIcle 1 2 sImply
means that the Issue of legItImate temporary employees IS stIll
unresolved as to whether or not they are covered by the
bargaInIng unIt, however that IS not the case before me, whIch
Instead Involves the use of agency employees to staff classIfied and
seasonal unclassIfied employees
I find that the InclusIOn of ArtIcle 1 2 IS not sufficIent proof
that the partIes agreed that agency employees fillIng permanent
and seasonal posItIOns could eXIst ou tSIde the collectIve
agreement Instead It seems that the partIes sImply recognIzed
that there may be other groups, whIch may not even eXIst at the
tIme the collectIve agreement was entered Into, whIch they could
agree to add to the bargaInIng unIt at some future date
In essence, If thIS employer were to be allowed an unfettered
rIght to staff permanent and seasonal posItIOns by uSIng agency
employees, It would serIOusly undermIne and perhaps destroy the
entIre basIs of the UnIOn's bargaInIng rIghts For such a powerful
rIght to eXIst, there would have to be clear and unambIguous
language In eIther the collectIve agreement or the governIng
legIslatIon I find that there IS no such clear and unambIguous
language In eIther the collectIve agreement or the governIng
legIslatIon
In summary I find that
(1) Based on the Pilon decIsIOn, there IS an ImplIed term In
thIS collectIve agreement that prohIbIts the employer
10
from uSIng non bargaInIng unIt employees to perform
bargaInIng unIt work
(2) ApplYIng the lOgIC and reasonIng behInd the Pilon
deCISIOn, the ImplIed term should be expanded to Include
a prohIbItIon agaInst uSIng contracted In agency
employees from performIng bargaInIng unIt work that
would otherwIse be done by classIfied and/or seasonal
unclassIfied employees
(3) The PublIc ServIce Act does not lImIt the power of the
GSB to order that the employer post Jobs pursuant to the
collectIve agreement or to order that the employer cease
and desIst from uSIng agency employees for work properly
In the bargaInIng unIt
(4) ThIs award IS not dealIng wIth the Issue of whether or not
the MInIstry can use agency employees to staff truly
temporary posItIOns
(5) There IS no past practIce that the MInIstry can rely upon
as thIS gnevance predates the start of the staffing
practIce In questIOn In the Tnllum Drug Program
I therefore find that agency employees were performIng work
of the bargaInIng unIt In the Tnllum Drug Program and that the
GSB has the JunsdIctIOn to both order the Employer to post
classIfied posItIOns and to cease and desIst from staffing seasonal
unclassIfied posItIOns WIth agency staff.
11
The partIes are to contact the RegIstrar to set up more
heanng dates
Dated at Toronto, thIS 20th day of February, 2002
Barry B FIsher, VIce ChaIr