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HomeMy WebLinkAbout1994-2061.Union Grievance.99-10-07 Decision o NTARlO EMPUJYES DE LA COURONNE CROW"! EMPLOYEES DE L 'ONTARlO GRIEVANCE COMMISSION DE -- SETTLEMENT REGLEMENT BOARD DES GRIEFS 180 DUNDAS STREET WEST SUITE 600 TORONTO ON M5G 128 TELEPHONE/TELEPHONE, (416) 326-1388 180 RUE DUNDAS OUEST BUREAU 600 TORONTO (ON) M5G 128 FACSIMILE/TELECOPIE. (416) 326-1396 GSB # 2061/94 2131/97 OPSEU # 94U996 97UOO 1 IN THE MATTER OF AN ARBITRATION Under THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT Before THE GRIEVANCE SETTLEMENT BOARD BETWEEN Ontano Pubhc ServIce Employees Umon (Umon Gnevance) Grievor - and - The Crown III RIght ofOntano (Mimstry of the SohcItor General & CorrecTIonal ServIces) Employer BEFORE FehcIty D Bnggs Vice ChaIr FOR THE Mary Anne Kuntz GRIEVOR Gnevance Officer Ontano Pubhc ServIce Employees Umon FOR THE Len Marvy EMPLOYER Semor Counsel, Legal ServIces Branch Management Board Secretanat HEARING September 8 1999 On August 26 1998 the Mimstry of the SOhCItor General and CorrecTIonal ServIces and the Dmon sIgned a Memorandum of Settlement and Release regarding the converSIOn of unclassIfied employees, Tms agreement followed a lengthy and comphcated negOTIaTIon process, It stated The Employer and The Dmon hereto agree that the followmg conSTItutes full and final settlement of the above noted Dmon Pohcy Gnevances and the attached gnevances hsted m Appendix A The partIes agree that the gnevors hsted m AppendIx A retam the nght to proceed to the Gnevance Settlement Board for a determmatIOn as to whether or not the provIsIons as set out m tills Memorandum of Settlement and the calculaTIon of hours have been appropnately apphed to them, The partIes agree that the gnevors hsted m Appendix A pOSITIOnS retaIn the nght to proceed to the Gnevance Settlement Board for a determmatIOn as to whether or not the 2 calendar year penod as defined m the Memorandum of Settlement IS the appropnate penod to be apphed to them for the purpose of determImng theIr ehgibihty for assIgnment to a newly created classIfied pOSITIOn, Article 31.15 - Unclassified Institutional Workers (Correctional Officers, Nurses, Cooks), Correctional Services Division Recogmzmg the difficulTIes m IdenTIfymg the specIfic employees backfillmg for specIfic purposes, and acknowledgmg the extraordmary CIrcumstances currently m place because of the decIsIons to hold vacanCIes to ease the Impact on mdivIduals of the sIgmficant workforce reducTIons m the mstItuTIOnS, the partIes agree to the followmg to correct the eXIstmg sItuaTIOn, but Without precedent or prejUdICe to future apphcatIOns of thIS or subsequent provIsIOns of the CollecTIve Agreement respecTIng the converSIOn of unclassIfied employees to classIfied status, Acknowledgmg that the employer has undertaken a change m ItS own pohcy to Immediately fill all eXISTIng ongomg mSTItuTIonal management vacanCIes as qwckly as possible but not later than 6 months from the sIgnmg of tills agreement, the partIes agree to the folloWing: 1 The employer agrees to calculate the total number of unclassIfied employees' hours, by class, m each InstItuTIOn for the penod June 1 1996 to May 31 1998 The total number of unclassIfied hours will Include pen ods of authonzed leave of unclassIfied employees and total hours will Include any hours wmch generated premIUm pay combIned WIth regular hours for unclassIfied employees provIded these hours do not exceed 80 hours WIthIn a gIven pay penod, 2 2 The employer will also calculate the total number of hours for approved leaves for classIfied employees by the same classes In each InSTItuTIon dunng the penod from June 1 1996 to May 31 1998 3 The difference between the total number of unclassIfied hours and the total number of approved leave hours for classIfied employees divIded by 1912 hours each calendar year will determIne the number of new classIfied pOSITIOnS to be estabhshed In each facihty If the result IS less than a whole number but greater than 85 the employer will create a new pOSITIOn, 4 The partIes acknowledge that at thIS partIcular TIme, for the purpose of these converSIOns, there IS an ongoIng need to estabhsh and fill the pOSITIOnS as IdenTIfied In paragraph 3 and that the employer Will not refuse to create these posItIOns solely because the on-gOIng need has not been estabhshed, 5 In future, the employer agrees to fill new ongOIng vacanCIes In accordance WIth the provIsIons of the collect1ve agreement. 6 In recogmTIon of the fact that unclassIfied CorrecTIonal Officers who have worked at least 1912 hours as a CorrecTIonal Officer will be reclassIfied from C01 to C02 effecTIve the sIgmng of tills Memorandum of Settlement In accordance With the pnncIples of ArtIcle 7 (pay AdmImstraTIon) of the Collect1ve Agreement. NotwIthstanding that thIS Memorandum of Settlement IS Without prejudice or precedent, the partIes agree that the above paragraph, can be rehed upon at the Gnevance Settlement Board as beIng With prejudice for the purpose of determImng only those prevIously filed gnevances pertaInIng to the dIfference between C01 and C02 pay levels of unclassIfied Correct1onal Officers who have completed the reqwred traImng, Process by which conversions of unclassified institutional workers (Correctional Officers, Nurses, Cooks) in the Correctional Services Division will occur A The pOSITIOnS estabhshed In paragraph 3 will be assIgned to unclassIfied employees who meet the cntena set out In paragraph (B) by class, by facihty provIded there are no surplus employees who qUalIfy for direct assIgnment. B To be ehgible for converSIOn Into a classIficaTIon, unclassIfied InsTItuTIonal workers must have completed a mImmum of 1912 hours, IncludIng authonzed leaves of absence, In each of two conseCUTIve years In that classIficaTIon, Those two consecutIve years must fall completely WItilln the penod April 1 1994 to May 31 1998 3 C Where the number of unclassIfied InsTItuTIonal workers who meet the cntena set out In paragraph (B) In a facIhty IS greater than the number of classIfied pOSITIOnS to be estabhshed, pOSITIOnS will be assIgned In accordance WIth the "pnncIple of semonty" The formula for calculaTIng "semonty" will be the total number of full TIme weeks worked up until May 31 1998 as an unclassIfied employee In the Ontano Pubhc ServIce back to the first break In employment wmch IS greater than 13 weeks In accordance WIth the pnncIples of ArtIcle 18 l(b) D UnclassIfied InSTItutIOnal Workers, ranked and hsted according to total number of full TIme weeks worked, Will be assIgned to pOSITIOnS at theIr facihty based on descending order of "semonty" In accordance wIth (c) above, E. IdenTIfied unclassIfied InsTItuTIonal Workers can elect In wnTIng WItilln three (3) workIng days not to accept an offered classIfied posItIOn, In the event tills occurs the classIfied pOSITIOn will be offered to the next mghest rankmg (in "semonty") unclassIfied employee on the hst In the same classIficaTIon, F All converSIOns and the resultant assIgnments to newly estabhshed classIfied pOSITIOnS Will be effectIve September 30 1998 G If the number of classIfied posItIOns to be estabhshed exceeds the number of ehgible unclassIfied employees In the same class, these addiTIonal pOSITIOnS will be posted In accordance With ArtIcles 6 and 20 no later than November 15 1998 and filled by December 31 1998 Article 31.15 - Process by which conversions for all other unclassified employees, Correctional Services Division will occur. 1 The employer will IdenTIfy workmg 1732,75 or 1912 straIght TIme hours, as apphcable, for each of two or more conseCUTIve years, takIng Into accent any approved leaves, Unless the partIes otherWIse agree or another appropnate penod IS determIned by an arbItrator pursuant to page 1 paragraph 3 the two year penod for each employee will be from June 1 1996 to May 31 1998 2 The employer will IdenTIfy the reason for the unclassIfied contact - l.e, backfilhng for approved leaves, backfillIng bemnd employees on temporary assIgnment and or secondment, exceSSIve workload, 3 Where an employee has worked the reqUIred number of hours because of exceSSIve workload or behInd an employee on secondment or temporary assIgnment or secondment will conTInue, the employer will convert the employee In accordance WIth ArtIcle 31 15 Such converSIOns will be completed by September 30 1998 4 4 Where specIfic unclassIfied employees have not worked the reqUIred number of hours for the purposes of converSIOn, the hours worked In the pOSITIOnS will be totaled With the other unclassIfied employees' hours In the same work sIte and same pOSITIOn and dIvIded by the apphcable 1732,75 or 1912 straIght tIme hours to determIne the number of classIfied full TIme pOSITIOnS to be estabhshed, These pOSITIOnS will be posted by November 15th, 1998 and filled by December 31 1998 In accordance wIth artIcles 20 and 6 If the result IS less than a whole number but greater than 85 a new posItIOn will be estabhshed, Hours worked backfilhng authonzed leaves of classIfied employees will not be Included m tills calculaTIon, The umon agrees to advIse the Gnevance Settlement Board that the pohcy gnevances cIted above have been Withdrawn wItilln 30 days of the SIgnIng of tills agreement and to further advIse the Gnevance Settlement Board that the gnevances IdenTIfied In AppendIx A have been settled or wIthdrawn no later than October 31 1998 The TImetable and process for the ImplementaTIon of thIS settlement are set out In Appendix B The partIes agree that Ms, F Bnggs IS to remaIn seIzed With respect to the InterpretaTIon and ImplementaTIon of tills Memorandum of Settlement, Including any disputes anSIng out of tills Memorandum of Settlement from the IndivIdual gnevors hsted In Appendix A After the sIgmng of the above Memorandum, the partIes set about to Implement the terms and provIsIons of theIr agreement. Not surpnsIngly gIven the compleXity of the agreement, there were disputes anSIng from the ImplementatIOn, In accordance With the Memorandum, the partIes have referred certaIn dIsputes to me for determInaTIon, In preparatIOn for the heanng Into these matters, the partIes agreed to a statement of facts, Those facts are as follows Pursuant to the partIes' Memorandum of Settlement dated August 26 1998 concermng the ConversIOn of UnclassIfied POSITIOnS, the partIes agree that the folloWIng conSTItutes part of the submIssIon to Vice-ChaIr FehcIty Bnggs on September 8 1999 1 It IS agreed that Ms, Bnggs conTInues to remaIn seIzed of dIsputes ansIng from the above-noted agreement. 2 It IS agreed that the attached hst of gnevances was IdenTIfied as Appendix A In the Memorandum of Settlement. It IS also agreed the partIes shall update hst of gnevances as AppendIx 1 5 3 It IS agreed that most of the Bsues gIVIng nse to these gnevances have been resolved, accordingly the Umon wIthdraws all of the gnevances except for those expressly IdenTIfied on that Appendix by the partIes as remaImng In dispute 4 It IS agreed that the partIes, In an effort to gIve the broadest possible InterpretatIOn to Item B of the Memorandum of August 26 1998 Included the folloWing types of authonzed leaves of absence In the calculatIOn of employees' ehgibihty for converSIon, - Pregnancy Leave (to a maXimum of 27 weeks Pregnancy (17), Parental (10)* - Parental Leave (to a maXimum of 12 weeks for male employees)* - WCB absences * - Penods of unpaId sIck leave - CompassIOnate leaves - Bereavement leaves - Umon leave - Canadian Forces leave *EnTItlement was based on averagIng hours In the 13 weeks worked pnor to the Injury or commencement of leave 5 The folloWing pen ods were not mcluded In the calculaTIon of ehgibihty, - pen ods when the employee IndIcated he/she was "unavailable" - penods of suspenSIOn for discIphnary reasons - vacatIOn penods and statutory hohdays - overtIme except to top a person up to 40 hours a week. 6 It IS agreed that eqwvalent hourly credit was gIven to everyone for all statutory hohdays and two weeks' annual vacaTIon, 7 It IS agreed that credIt for the five 5 week penod of the OPS stnke In March 1996 was dealt With as follows hours In pnor 13 weeks (averaged) X 5 = hours credIted for converSIOn purposes, Actual hours worked were removed or substItuted With tills formula, 8 It IS agreed that no dIspute eXIsts between the Employer and the Umon concernIng the calculaTIons completed by the Employer pursuant to Items 1 2, and 3 or the Memorandum of August 16 1998 The partIes estabhshed a JOInt CommIttee to deal With ImplementaTIon Issues, The commIttee had equal representatIOn and operated on the basIs on consensus, ThIS veillcle allowed the partIes to resolve a great many of the disputes that arose after the sIgmng of the Memorandum, 6 It IS not my IntenTIon to set out, In detail, the submIssIons of the partIes' on each of the Issues In dispute It IS sufficIent to say that I was provIded With a complete artIculatIOn of the pOSITIOn of each party and the argument to substantIate that VIew I very much apprecIated the clanty provIded by the partIes regarding each of the Issues, It was apparent from the August 26 1998 Memorandum of Settlement and the resultIng ImplementatIOn process that the partIes made every effort to resolve the outstandIng matters relaTIng to the converSIOn of unclassIfied staff They were, In large measure successful and It IS not surpnsIng that a handful of Issues needed the attentIOn of thIS Board, I will set out the outstanding Issues In for form of a quesTIon and provIde the determInaTIon for each, To what extent, if any, are the parties required to revisit or reconsider further information once a decision from the Joint UnionlManagement Implementation Committee has been issued to grievors? Tills matter has ansen subsequent to vanous CIrcumstances, Some gnevors have sImply asked the commIttee to reconsIder a decIsIon Without provIding any new InformaTIon or any reason for the request for reconsIderaTIon, Others have raIsed new Issues or provIded facts not prevIOusly raIsed folloWIng the commIttee's decIsIon and have asked for a reconsIderaTIon on the basIs of that new InformaTIon, It was clear from the partIes' submIssIons that the JOInt CommIttee was frequently asked to reVIew matenal and, to ItS credIt, It frequently did re-consIder the partIcular sItuaTIOn of vanous gnevors based on new matenal provIded, Gnevors were Informed of the CommIttee's decIsIon by a JOIntly wntten letter The process estabhshed by the partIes provIded that complaInants were notIfied of a deadhne for further InformaTIon and submIssIons to be gIven to the JOInt CommIttee, Indeed, a second nOTIce was gIven to ensure that every opportumty was gIven to employees, The commIttee was reluctant to estabhsh a deadhne because It wanted to avoId mISSIng the opportumty of consIdenng all relevant InformaTIon and It was probably for tills reason that It chose to re- 7 consIder some matters, However reVIews caused occasIOnal delays In convertIng certaIn pOSITIOnS, Such delays were In the Interest of no one The converSIOn of posItIOns bnngs With It many adjustments for the people who are beIng converted that should be done as qwckly as IS pracTIcable In my VIew the JOInt CommIttee IS not reqUIred to conTInue to reVIew and reconsIder Issues already addressed and determIned, It has met ItS mandate To be clear any dIspute or gnevance filed pnor to August 26 1998 where the commIttee has rendered ItS decIsIOn, the matter has finally decIded, There IS no need for the JOInt CommIttee to reconsIder those gnevances further While I am seIzed of ImplementaTIon dIsputes as set out In the final paragraph of the Memorandum of Settlement, I am not seIzed With gnevances filed subsequent to August 26 1998 What is the meaning of "by facility" found at paragraphs A, B, C, D and Appendix B of the Memorandum of Settlement dated August 26, 1998? Some gnevors have taken the pOSITIOn they have access to converted pOSITIOnS created In InSTItuTIons other than the one In whIch they were employed as at May 31 1998 I dIsagree In my VIew the Memorandum contemplates Integnty of the worksIte In terms of pOSITIOnS to be converted, One example provIded was In the Sudbury regIOn, I understand that no unclassIfied employee was ehgible for converSIOn at Cecil Faser notWIthstanding the fact that five new pOSITIOnS were created, Across town at the Sudbury Jail, there were more ehgible unclassIfied employees than there were newly created pOSITIOnS, Some gnevors at the Sudbury JaIl took the posItIOn that they were enTItled to the pOSITIOnS at Cecil Faser SImply put, there IS notillng In the Memorandum of Settlement between the partIes to substantIate such a claIm, Willie I can understand that some gnevors at the Sudbury Jail mIght have found tills sItuaTIOn frustraTIng, the are not enTItled to pOSITIOnS at another InSTItuTIon, 8 UnclassIfied employees receIved credIt for hours worked at other InSTItuTIons, However they were only enTItled to be converted Into pOSITIOnS WIthIn the facihty where they were located on May 31 1998 Some unclassified staff claim entitlement to conversion based on meeting the eligibility criteria after May 31,1998. Are they entitled to conversion? Whenever there IS a deadhne or cutoff pOInt estabhshed In a Memorandum of Settlement such as IS before me, It IS always gOIng to occur that some people will meet the deadhne but a small margIn and some will mISS the date by a matter of days, There was discussIOn at the heanng about the dISappOIntment of those employees who were close to meetIng the ehgibihty cntena but were beyond the date of May 31 1998 It IS not dIfficult to understand the frustraTIon of such a sItuatIOn, The Gnevance Settlement Board has been faced With tills Issue In the past. I chaIred a number of gnevances that arose from a Memorandum of Settlement regarding converSIOn between the Mimstry of Natural Resources and the Umon, In Re Trybus et ai, I consIdered the Importance of respect1ng a cutoff date and my VIew has changed In tills Instance, Those gnevances were demed, The partIes agreed upon a certaIn date for a cut off pOInt and that date must be respected, If the partIes moved the cutoff pOInt by a week or two, there would still be employees who just faIled to meet the cntena, Notillng IS resolved by mOVIng the date Further alloWIng excepTIons just causes sIgnIficant frustraTIon to the process, In sItuatIOns such tills It IS ImperaTIve for the partIes to amve at a date both beheves to be reasonable and to have a consIstent apphcatIOn of the Memorandum and not make excepTIons, I am sure that there were occaSIOns when the partIes were tempted to be flexible With the cut off date gIven some of the partIcular fact sItuaTIOnS before them, However In my VIew the partIes were nght to maIntaIn the Integnty of the date Without excepTIon, To waver and allow certaIn excepTIons would only lead to further frustraTIons, IrrespecTIve of whether gnevors mIssed the ehgibihty date of May 31 1998 by 9 days or weeks or years, such failure IS, In and of ItSelf, determInaTIve of the matter Tills Board will allow no excepTIons, Are grievors who failed to meet the eligibility date of May 31, 1998, entitled to the excess converted positions resulting from circumstances where there were more positions to be converted than employees entitled to be rolled over? No As menTIoned above, employees who failed to meet the converSIOn cntena as of May 31 1998 are not enTItled to be converted under the Memorandum of Settlement under any CIrcumstances, To what extent, if any, should a vacancy that was created after May 31,1998 be treated as an ongoing entitlement to conversion? I understand that there are some gnevors who have alleged that the Memorandum of Settlement should contInue to apply SpecIfically It was suggested that postIngs arISIng after May 31 1998 should be converted or offered only for unclassIfied employees, AgaIn, I disagree, The Memorandum estabhshed a tIme frame for converSIOn of pOSITIOnS and unclassIfied employees, Once past that obhgaTIon, the collecTIve agreement apphes, Accordingly pOSITIOnS created after May 31 1998 are to be posted and filled In accordance With the terms and provIsIOns of the collect1ve agreement. What is the criteria for conversion of positions after May 31, 1998? Cntena for converSIOns after May 31 1998 are provIded at ArtIcle 31 15 1 1 of the collectIve agreement. Some institutions had more eligible unclassified staff than new positions. Does the Memorandum of Agreement contain a guarantee to a position for every eligible person, either implicitly or expressly? 10 I understand that there were no dIsputes between the partIes concernIng the number of posItIOns to be created resulTIng from the Memorandum of Agreement. Indeed, It was agreed that the Employer properly apphed the formula for determImng the number of pOSITIOnS to be created, I can find notillng m the Memorandum of Agreement that would lead me to find that the Employer was obhged to create a pOSITIOn for every employee who met the ehgibihty cntena, Indeed, If that were the case, there would have been no need for an agreement regardIng how to determIne the number of new classIfied pOSITIOnS to be estabhshed at each facihty as IS found on page two at paragraph three of the Memorandum of Agreement. At one institution some grievors claim that they have been unfairly disadvantaged because unclassified hours were unusually low due to riots in February of 1996 and December of 1997 Unclassified staff were laid off or lost hours as result of the riots. Is it prejudicial to these employees to use the same time period (June 1, 1996 to May 31, 1998) for the calculation of positions to be converted or for the calculation of individual eligibility for conversion? While I understand some IndivIduals at tills InSTItuTIon mIght feel disadvantaged by certaIn condiTIons dunng the ehgibihty penod, the partIes had to estabhsh a penod of TIme that was most appropnate for the majonty of the employees In the Mimstry It IS not surpnSIng that not all IndivIduals or all InSTItuTIons approve equally of the date, All will be affected differently and occasIOnally for operaTIonal reasons some mIght feel prejudiced, However there IS notillng about the TIme frame that IS Inappropnate or prejudicIal, In my VIew By desIgn, unclassIfied employees are scheduled to work as they are needed, The staffing needs of an InSTItuTIon will alter depending on operaTIonal reqwrements, Some jails had umts closed dunng the ehgibihty penod, The jail at Issue had a layoff due to nOTIng, It IS possible that some InSTItuTIons had hIgh needs dunng that same penod, Circumstances will vary around the ProVInce, That anyone mSTItuTIon had fewer unclassIfied hours dunng the ehgibihty penod than It did dunng an earher or later penod does not constItute prejUdICe, Further there IS notillng In the 11 Memorandum of Agreement that would allow for any alteraTIon of Its terms depending on vanous CIrcumstances, Two pregnant correctional officers required accommodation. The only accommodation available was one position that was job-shared by the two women. One now claims that she would have met the number of hours needs for conversion but for the reduced hours. Was she discriminated against? According to the partIes' submIssIons, the gnevor made no claIm of discnmInatIOn at the TIme of the accommodaTIon, In my VIew In order to make a finding of discnmInaTIon regarding her failure to be converted, the gnevor would have had to object to the accommodatIOn at the TIme It would not be appropnate to allow a retroaCTIve claIm of discnmInaTIon for reasons that could not have been foreseen at the TIme of the accommodaTIon, The actual accommodatIOn brought no allegaTIon of discnmInaTIon and I therefore will make no such finding at tills TIme, Should an approved leave of absence to get married be included in the calculation of eligibility for conversion? As an unclassIfied employee the gnevor receIved no vacaTIon enTItlement under the collect1ve agreement. He took an approved leave of absence to get mamed because of hIS lack of paId vacaTIon, It IS ills allegaTIon that the lack of vacaTIon enTItlement cannot now be held agaInst illm for the purposes of calculaTIng ehgibIhty for converSIOn, I tillnk not. The partIes agreed to a formula for converSIOn that Included gIVIng credIt across the board for vacaTIon days and statutory hohdays, The gnevor like others, got the benefit of that and IS not enTItled to more Should hours worked in any classification during the eligibility period count for conversion to a particular position? An example was gIven of an employee who had a number of hours worked as a RecreatIOnal Officer He alleged those hours worked as a RecreaTIonal Officer should be counted In determImng ills ehgibihty to convert Into the posItIOn of CorrecTIonal Officer I cannot agree, 12 According to the Memorandum of Settlement, ehgibihty for converSIOn Into a classIficaTIon IS based on hours worked In that classIficatIOn and not, as alleged, hours worked In any posItIOn for the Mimstry Can a grievor now claim that failure to post "secondments" during the eligibility period prejudiced his opportunity to achieve sufficient hours to be allowed to convert? No It IS my understandIng that there were no gnevances filed at the tIme that the above referred to secondments were not posted, I also understand that the secondments that the gnevor rehed upon were for temporary pOSITIOnS, The allocatIOn of temporary assIgnments IS WithIn the purvIew of the Employer There IS no provIsIon In the collect1ve agreement that obhges the Employer to post temporary assIgnments, Accordingly the matter IS not an arbItrable, Was the failure to include overtime worked in the conversion criteria prejudicial to employees who lost hours due to riots in the worksite? It was the pOSITIOn of the gnevors In tills matter that every hour of overtIme should have been counted In the calculaTIon agreed to by the partIes, The formula for overtIme was different from that. As menTIoned earher the partIes agreed on VarIOUS terms and provIsIons that were the most beneficIal to the majonty of employees, It follows that some employees mIght receIve less benefit than others, Tills IS the result of compromIse and It goes WIthOUt saYIng that the Umon acted In what It thought was the best Interest of ItS members generally There IS no doubt that the Memorandum of Settlement provIdes an overall greater benefit to unclassIfied employees In the Mimstry of Correct1onal ServIces than those found In the collect1ve agreement. The partIes are to be commended on amvIng at a solutIOn that takes Into account not only the general pnncIples set out In the collect1ve agreement but also the long-standIng concerns of employees In the workplace 13 I conTInue to remaIn seIzed of matters In accordance WIth the Memorandum of Agreement of August 26 1998 Dated In Toronto, thIS 7th day of October 1999 ~ . . . I I. ;~~ I" _, ' 1:1 'f:- ; ; .~- _ - _ r __ I . ~ . FehcIty D Bnggs 14