HomeMy WebLinkAbout1994-0147.STEPHENS99_06_16
ONTARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
1111 GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 600, TORONTO ON M5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G 1Z8 FACSIMILE/TELECOPIE (416) 326-1396
GSB # 0147/94
OPSEU # 94C132
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEV ANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Umon
(Donna Stephens)
Grievor
- and -
The Crown In RIght of Ontano
(MInIstry ofCommumty and SocIal ServIces)
Employer
BEFORE Nimal V DIssanayake V Ice ChaIr
FOR THE Susan PhIlpott
GRIEVOR Counsel, KoskIe MInsky
BarrIsters & SolICItors
FOR THE Peter M. Rusk
EMPLOYER Counsel, Legal ServIces Branch
Mimstry of Commumty and SocIal ServIces
HEARINGS August 18 1995, January 27,1997,
June 16 July 13 14, 1998,
January 27, 28, February 4, 18, 1999
(Wntten submIssions on remedy completed on March 9,
1999)
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AWARD
The Board is seized with a grievance dated December 7, 1993,
filed by Ms Donna Stephens The statement of grievance is as
follows
In May of 1991, I grieved my dismissal During this
time my employer withheld pertinent information that
caused me to lose the opportunity to apply for a
full-time position
Ms Stephens commenced employment at the Southwestern Regional
Centre (SRC) in Blenheim, Ontario in 1964 While there was
confusion about the classification of the positions she held since
1964, what is established is that Ms Stephens continued to be
employed at the SRC until 1991 with two brief interruptions related
to her pregnancies SRC lS a facility providing residential and
treatment serVlces to severely handicapped persons In 1991, Ms
Stephens was working at the SRC as a Special Needs ConsultaDt as an
unclassified employee At the time she had approximately 20 years
of experience working In various capacities with developmentally
handicapped persons at the SRC For 10 years she was employed as
a full-time classified employee, and the rest as a contract
(unclassified) employee or as a self employed consultant
The grievor's problems arose early in 1991 when it was
announced that a number of positions at the SRC, which had been
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,.. occupied by unclassified employees, were to be converted to
classified positions and posted, as required by the collective
agreement Ms Stephens was notified that as a result her services
as an unclassified employee performing special needs duties would
no longer would the required At the time, several postings were
advertized including one for 12 positions titled Developmental
Service Worker, classified as Counsellor 2 Residential Life (RC2)
Ms Stephens applied for one of these positions This particular
posting listed 9 "qualifications", one of which was "successful
completion of the Developmental Service Worker Certificate Course
or the Independent Work Study Program"
The employer at the time had in place a policy titled "the
Staffing Standards" which set out the credentials required for
various positions within the Minlstry The credentials required
for the position of RC2 were described as follows
Community college diploma in a field directly
related to the positions, i e Developmental
Services Worker diploma, Child Care Worker
diploma
OR
A Bachelor's degree from a university of
recognized standing or a non-related college
diploma, a minimum of one years experience at the
Counsellor 1 Residential Life, Child Care Worker
1 or Medical Assistant 1 levels, and successful
r
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completion of an Individual Work Study Program
(IWSP)
OR
At least four credits towards a Bachelor's degree
or a community college diploma program or, for
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those who are mature applicants and have grade
ten education, a minimum of 18 months and a
maximum of 24 months at the Couns I Res Life,
C C W 1, or Med Ass't (and) successful
completion of IWSP during this time period
Requests for exemptions or equivalency
assessments should be forwarded on a case by case
basis to the Policy and Initiatives Section,
Human Resources Branch
(Emphasis added)
The Independent Work Study Program (IWSP) referred to in the
job posting and the emphasised portion of the Staffing Standards
was offered internally by the SRC in the 1970s and 1980s, but was
no longer offered after 1986 Ms Stephens had not completed this
program The DSW was a 2 year college diploma Ms Stephens had
completed many, but not all, of the courses required to receive the
diploma She would have had the-DSW designation had she completed
the 6 week re-training offered by the employer In early 1970
However, Ms Stephens had missed that As a result, she did not
possess the educational credentials required by the posting for
which she had applied
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Ms Stephens felt that it was an absurd situation, for she
felt that the posted positions were the same as the position she
had occupied for several years quite competently She approached
Ms Pat Duquette, the Acting Manager of Human Resources Ms
Duquette undertook to ascertain whether Ms Stephens had
"equivalency" to the DSW designation, and if not what she had to do
to compensate for the 6 week retraining she had missed
A substantial amount of evidence was tendered about various
communications which followed between Ms Duquette and Ms Stephens
and between Ms Duquette and the Toronto Head Office of the
Ministry It is not useful to review that evidence in detail It
suffices to note that Ms Duquette sought a decision from the
Toronto Head Office in deciding whether Ms Stephens had the
equivalency to the DSW Suggestions were made to Ms Stephens that
she may be able to acquire equivalency to the DSW by completing
certain courses of study Ms Stephens commenced doing the courses
as suggested, in an attempt to acquire the required educational
credentials prlor to the competition However, ultimately Ms
Stephens was advised that the only way she could qualify was by
doing the courses to complete the full DSW Unfortunately, there
was no time for Ms Stephens to do all of the missing courses in
time for the competition in question
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While inquiries were being made about Ms Stephens'
equivalency status, Ms Duquette allowed her to participate in the
competition However, when the results were released Ms Stephens
was not one of the successful candidates As a result, by letter
dated May 30, 1991, Ms Stephens was informed by Ms Duquette as
follows
Due to the recent Developmental Service Worker
competition, and the subsequent filling of the
Residential Counsellor 2 vacancies within the
facility, it has become necessary to formally
notify you that your current contract will be
terminated effective June 9, 1991
I would like to thank you for your care and
concern for the clients during your employment at
Southwestern Regional Centre, and encourage you
to apply for any future opening that may be
avallable
Ms Stephens lodged a grievance dated June 26, 1991 stating "I
grieve that I have been unjustly disciplined and dismissed from my
employment at the Southwestern Regional Centre"
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Thls grlevance was settled by mlnutes signed on August 19,
1991 as follows
Without prejudice and without precedent the
parties hereto agree to a full and final
settlement of this grievance on the following
terms
1 The Ministry agrees to issue to the
Grievor a full-time, unclassified
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contract as an MRC Trainee, commencing
June 3, 1991, and ending on the date of
acceptance of this Memorandum of
Settlement
2 The Ministry agrees to reinstate the
attendance credits that were standing as
of June 2, 1991 No additional wages
above those actually earned will be paid
for the period of June 3, 1991, to the
date of acceptance of this Memorandum
3 The Ministry agrees to issue to the
Grievor a 12-month, full-time
unclassified contract for the period
commencing the date of acceptance of
this Memorandum of Settlement
4 The Ministry agrees to lssue to the
Grievor a 6-mon th, full-time
unclassified contract, effective
immediately upon expiry of the 12-month
contract mentioned above in Paragraph 3
5 The Ministry and the Grievor agree that
the Ministry is under no obligation to
issue any further contracts (beyond
those described above in Paragraphs 2,
3, and 4) to the Grievor
6 The Ministry agrees to recognize that
the grievor has completed the dacum
requirements of the Independent Work
Study Program
7 Prior to the explry of the contract
mentioned above in Paragraph 4, Grievor
agrees to show to the Ministry proof of
successful completion of the following
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college courses (list of 5 courses
omitted)
8 The Ministry agrees that, upon
completion of the above requirements
they will provide the grievor with a
certificate attesting to her successful
completion of the Independent Work Study
Program
9 The Ministry and the Grievor agree that
after the grievor has successfully
completed the above-mentioned courses,
grievor will be eligible to compete for
any vacant classified Residential
Counsellor 2 positions at Southwestern
Regional Centre
10 The Ministry and the Grievor agree that
the Grievor will not be eligible for
educational assistance in the form of
paid leave or payment of tuition fees
during the above-described time period
11 The Ministry agrees to arrange the
grievor's work schedule to accommodate
her attendance at college classes
12 Grievor agrees 'to withdraw the
grievance
Ms Stephens completed the courses specified in para 7 of the
minutes, and qualified herself with the DSW designation in November
of 1991 At this time she was on a full-time contract position
She now had the required educational credentials to apply for a
9
classified RC 2 position, but no vacancy was forthcoming Yet Ms
Stephens continued as a contract employee and was willing to wait
for a RC2 vacancy However, at the end of her contract, she was
not given another full-time contract Instead, the employer gave
her a contract on a call-in basis which did not provide her full
time hours She understood that an untrained employee had been
offered a full-time contract instead of her
Ms Stephens testified that she was upset and distraught over
this turn of events She always felt that "something was not
right" about the way her situation was handled by Ms Duquette In
the period leading up to her 1991 grievance She had a suspicion
that Ms Duquette had not been truthful with regard to the
information she gave about her dealings with the Toronto Head
Office with the advice of the union, Ms Stephens sought
disclosure of her 1991 grievance file, specifically seeking
disclosure of correspondence between Ms Duquette and the Toronto
Head Office In the period preceding the termination of her
contract Ms Duquette resisted her request for disclosure
claiming that the information was privileged Ms Stephens made a
formal appeal under the Freedom of Information Act, and ultimately
was successful in getting an order for disclosure dated October 19,
1994 In the meantime, Ms Stephens had filed the instant
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grievance dated December 7 , 1993 The disclosure pursuant to the
FOI order in October 1994 gave Ms Stephens access to a number of
pieces of correspondent between Ms Duquette and the Toronto Head
Office
The disclosed documents indicate that on March 18, 1991, Ms
Marilyn Sacco, HR Representative wrote to the then Administrator of
the SRC, Mr Lloyd Jackson, setting out Ms Stephen's employment
history and recommending that Ms Stephens' case be referred to
"the Policy and Initiatives Section, Human Resources Branch, who
will review her experience and training for possible equivalency"
(Emphasis added) Mr Jackson approved this recommendation and Ms
Duquette became involved On April 15, 1991 she wrote a letter to
Mr Tod MacKellar, Manager of the Policy & Initiatives Branch in
Toronto, inter alia, setting out Ms Stephen's employment
background, and stating "Given her training, background and work
history, I am requesting your view of her experience and training
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as it relates to the DSW 2 position"
On April 23, 1991 Mr MacKellar responded as follows
In response to your letter of April 15, 1991, we
have reviewed the material regarding Donna
Stephens with respect to her education and
experience In relation to the requirements for
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the position of Counsellor 2, Residential Life
Based on the well-researched and thorough
synopsis which you submitted, our response is as
follows
1 With respect to the Ministry's current
staffing standard for the Counsellor 2,
Residential Life position, it does not
appear that Mrs Stephens possesses the
primary academic requirement, i e DSW
diploma (formerly MRC certificate) from
a community college Your documentation
indicates that Mts Stephens did not
complete training requirements In the
late 1960's (due to leave of absence)
for the MRC certificate which would have
qualified her for the Counsellor 2,
Residential Life position During her
years of subsequent employment at SWRC,
she did not obtain this certificate
either through a community college or by
means of an in-house individual Work
Study Program Consequently, Mrs
Stephens should not be appointed to the
full working level of a classified
Counsellor 2, Residential Life position
upon the initial converSlon of her
unclassified position,
HOWEVER
2 Mrs Stephens does possess one of the
accepted equivalencies for an underfill
appointment to the Counsellor 2,
Residential Life position, i e she is a
mature applicant with a grade 10
education Therefore, she can be
appointed on an underfill basis as a
Counsellor 1, Residential Life for a
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minimum of 18 months and maximum of 24
months during which time she must
successfully complete an Individual Work
Study Program (See staffing standard
which is enclosed) Following
successful completion of the IWSP and
the 18 to 24 month experiential
component, the underfill would be
removed and she would be appointed to
the Counsellor 2 level We note your
comment that Southwestern's policy is
not to underfill Counsellor 2 positions,
however, the Ministry staffing standard
does allow for certain equivalencies to
the DSW certificate, and when applicants
present themselves with these
equivalencies, it is Ministry policy (as
set out in the staffing standard) to
consider these equivalencies, where
appropriate This is the situation in
which your facility now finds itself
Conclusion
Mrs Stephens' employment cannot be terminated on
the basis of the staffing standard It is our
strong recommendation that Mrs Stephens be
appointed to a classified Counsellor 2,
Residential Life posltion on an underfill basis
at the Counsellor 1 level for a minimum of 18
months to a maximum of 24 months, during which
time she must successfully complete an IWSP
program Once the experiential and IWSP
components of the underfill are completed, she
can then be confirmed at the Counsellor 2 level
You will note that the staffing standard also
allows individual managers in conjunction with
the Facility Administrator the discretion to
"reduce" the experiential component of the
underfill after the IWSP has been completed
Considering the years of relevant experience
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which Mrs Stephens possesses, you may wish to
keep this in mind
If you have any further questions or concerns,
please contact Karen Braybrook, Policy Advisor,
at 327-4793
On May 2, 1991, Ms Duquette wrote to Mr MacKellar again It
included the following paragraph
Donna is currently enrolled in several courses at
St Clair College and I spoke recently with the
college's counsellor about the "Human Services
Certificate Program" This certificate program
is apparently accepted by the associations in the
local area I am attaching a description of the
courses that are required for the certificate
program Please review the material and advise
me if this certificate program could be
considered equivalent to the course work material
for an IWSP
The courses Ms Stephens was enrolled in and her status in
each course were listed in the letter On May 14, 1991, Ms Karen
Braybrook, a HR Policy Advisor wrote to Ms Duquette on behalf of
Mr MacKellar, advising that t-he HR Branch did "not have the
expertise or information to be able to assess the equivalency of
the Human Services Certificate courses to courses which may be
taken as part of an IWSP program"
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Having read these documents for the first time in October of
1994, Ms Stephens decided to proceed with her grievance dated
December 7, 1993
Arbitrability
The employer has ta ken the position that as a result of the
settlement of Ms Stephens' 1991 grievance, the present grievance
is res judicata The union submits that res judicata does not
apply because the issues raised in the present grievance are
substantially different than the issues in the grievance settled
Alternatively, the union submits that the Board should set aside
the settlement of the 1991 grievance because Ms Stephens was
induced into settling that grievance as a result of misinformation
and failure to provide material information, on the part of Ms
Duquette
One of the key requirements before the doctrine of res
--
judicata can operate as a bar to the arbitration of a second
grievance is that the grievance must deal with the same subject
matter as the grievance previously settled See, Re R Angus,
division of Finning Ltd , (1992) 29 LAC (4 th) 102 (Beattie)
This requirement is also reflected in the oft-quoted passage from
15
Re City of Sudbury, (1965) 15 LAC 403 (Reville) at p 404,
quoting from Re Mueller Ltd , (1961) , 12 LAC 131 (Reville)
The grievance procedure lS designed to
provide members of the bargaining unit and the
union with a method of orderly precessing their
respective grievances In order to avoid the
expense inherent in the arbitration process the
procedure provides for bona fide efforts to be
made by both the grievor and management to settle
the dispute at various stages and at various
levels It follows, therefore, that if the
grievor and/or the union actually or impliedly
accept the decision of management they should not
be allowed to have second thoughts on the matter
and reprocess essentially the same grievance at a
later date If this were to be allowed,
management would never know whether, in fact, its
decision had been accepted by the individual
grievor or the union representing him, and
management would be plagued and harassed in what
would be a plain abuse of the grlevance
procedure
(Emphasis added)
It has been also held that in deciding whether res judicata
applies, considerations of efficiency and finality must be weighed
against the substantive issue in question, and that prima facie the
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rights created by the collective agreement should be dominant and
should give way only to a demonstrated abuse of process See Re
-
Governing Council of University of Toronto, (1975) , 10 LAC (2d)
417 (Adell)
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The evidence indicates that in Ms Stephens' 1991 grievance
the focus was the employer's right to terminate her The evidence
was that during the grievance procedure the discussions centred
around how Ms Stephens may be allowed to attain the educational
requirements in order to qualify as a DSW There was no discussion
as to whether Ms Stephens had "equivalency" on the basis of her
employment experience The discussions during the grievance
procedure nor the minutes of settlement touched upon the
competition process Ms Stephens participated in The present
grievance, in its written form, only referred to the withholding of
pertinent information by the employer However at arbitration the
union raised, without objection from the employer, as its primary
grounds, an alleged breach of article 4 3, l e that the employer
failed to properly assess Ms Stephens' qualifications and ability
during the competition process An allegation of a breach of
article 4 3 formed no part of the grievance procedure or the
settlement of the 1991 grievance Therefore the primary issue
raised in the present grievance is not the same, and res judicata
does not bar the arbitration of the present grievance
There is an additional reason for not applying res judicata in
the present case The evidence indicates that at the time the
grievor signed the minutes of settlement, she had not been made
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aware that the head office, which the employer considered to be the
authority on deciding equivalencies, had concluded, inter alla,
that "Mrs Stephens does possess one of the accepted equivalencies
for an underfill appointment to the Counsellor 2, Residential Life
position", and had stated that "Mrs Stephens' employment cannot be
terminated on the basis of the staffing standard" The employer
submitted that it was not bound by these opinions and
recorrunendations of the head office, and that they were based on
incorrect assumptions and misconceptions on the part of the head
office Whether or not that is correct, the point is that there is
no reason to doubt Ms Stephens' testimony that had she been given
this information that the head office supported her own position,
she would have had a much stronger bargaining position, and would
never have agreed to the terms of settlement as she did In the
present grievance she is relying on that information which she only
received after she had signed the minutes of settlement Until
then she was deprived of that information because of the employer's
mistaken belief that the information was privileged In the
circumstances, Ms Stephens' present grievance relying on this
newly acquired information cannot reasonably be seen as an abuse of
process
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For all of those reasons the Board concludes that the grievor
is not barred from arbitrating the present grievance
The Merits
The union made several arguments in support of Ms Stephens'
grievance As noted, its primary position is that the employer
failed to properly assess Ms Stephens' qualifications and ability
as required by article 4 3 of the collective agreement That
provision reads
4 3 In filling a vacancy, the Employer shall
give primary consideration to
qualifications and ability to perform
the required duties Where
qualifications and ability are
relatively equal, length of continuous
service shall be a consideration
The evidence before the Board clearly establishes a number of
thlngs Ms Stephens missed the 6 week re-training offered by the
employer early in 1970 because at the time she was away on
maternity In any event she would not have received that re-
training at that time because she was not employed in a residential
setting The evidence is also that the retraining had a
predominantly programming content It is beyond doubt that it was
this missing 6 week retraining which caused the employer to deem
Ms Stephens to be not qualified as a DSW In response to a
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question from the Board, Ms Duquette had no hesitation confirming
that Ms Stephens would have been qualified as a DSW if she had not
missed that 6 week re-training
It is also clear that the employer's concern was not about Ms
Stephens' actual skill and ability to perform the duties of the
posted positions, but the lack of the posted formal education as a
technical requirement This was made abundantly clear during Ms
Duquette's testimony She testified during her examination-in-
chief that in her Special Needs position Ms Stephens "was
regarded highly as a good counsellor and respected by her
managers" Under cross-examination when union counsel put Ms
Stephens' performance appraisals to her and asked what they
indicate about Ms Stephens' work performance, Ms Duquette
replied, "Even without looking at these I can say she was an
excellent staff" Ms Duquette agreed that the appraisals
indicated that Ms Stephens had "excellent prograrmnlng skills", and
that she did all aspects of the job in a very satisfactory manner
Union counsel then put before Ms Duquette the position
specification for Ms Stephen's Special Needs position and the
following exchange followed
Q She did these duties for about 8 years?
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A Yes
Q From 1983 to 1991?
A Yes
Q You knew that?
A Yes
Q This specification details the duties
she performed?
A Yes
Q In 1991, this Special Needs position was
converted as a classified RC 2 job and
posted?
A Yes
Q Requirements for it became a DSW or
equivalent?
A Yes
Q Before that Ms Stephens did the same
duties for 8 years but no DSW was
required?
A Yes
Q How does the Job In this positlon
specification differ from the posted
classified job?
A I wouldn't say it did I'd say its
essentially the same job
Subsequently, counsel suggested that if Ms Stephens was
lacking the 6 week retraining, her experience more than made up for
it Ms Duquette responded, "No I agree she was an excellent
employee But that does not make up for her education lapses"
When asked what that education would add to Ms Stephens ability to
be a RC2, Ms Duquette replied, "That's not the point There was
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an educational designation prescribed We had some 700 employees
in the classification who had met this prescribed education one way
or the other" She agreed with the proposition, "So no matter what
she had done, what experience she had - if she didn't have the
formal education prescribed she would not get a position "
It is evident that when Ms Duquette set out to ascertain Ms
Stephens' equivalency, she intended to consider Ms Stephens'
experience as part of the equivalency Thus In her letter dated
April 15, 1991 to Mr MacKellar she wrote "Given her training,
background and her work history, In am requesting your review of
her experience and training as it relates to the DSW position"
This was consistent with the recommendation by HR Rep Ms Sacco to
the Administrator that Ms Stephens' case be referred to the Policy
and Initiatives Section, "who will review her experie-rce and
training for possible equivalency"
While the employer intended, at least initially, to consider
Ms Stephens' experience as part of the assessment of her
equivalency, in reality that was not done When union counsel
asked Ms Duquette whether she gave any consideration to Ms
Stephens' significant experience as an equivalency to the missing
formal education, she replied that she had no authority to
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determine equivalency and that it was Mr MacKellar who had that
authority under the staffing standards However, she also agreed
that she did not inform Mr MacKellar of the duties Ms Stephens
had performed in her Special Needs position and speclfically that
there was no material difference between the duties she had
performed competently for some 8 years and the duties of the posted
job
Mr MacKellar prefaces his letter dated April 23, 1991 by
stating that "We have reviewed her education and experience "
Howeve r , there can be no doubt that Mr MacKellar in actual fact
did not give any consideration to experience as a relevant factor
in assessing whether Ms Stephens had equivalency to a DSW The
extent of his assessment was to investigate whether Ms Stephens
had formal education other than those specified in the staffing
standards, which may be considered equivalent His review was to
see if she had equivalency to the posted educational requirement
through some form of other formal education - courses, diplomas,
certificates etc Experience was not considered relevant to the
issue of equivalency This was made clear by Ms Karen Braybrook,
Human Resources Policy Advisor, who worked closely with Mr
MacKellar on Ms Stephens' case She candidly testified under re-
examination that her understanding was that under the staffing
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standards, experience alone could never qualify an individual who
lacked the prescribed educational qualifications She stated that
she was not aware of anyone who was considered qualified based on
experience alone As noted earlier, Ms Duquette was also of the
view that regardless of an individual's actual skill and ability
based on experience, she would not be awarded a position if she did
not possess the posted formal educational designation
It is significant to note that this is not a case of a grievor
who had no related formal education But for the missing 6 week
retraining, Ms Stephens would have been found to possess the
required educational requirements In terms of the DSW
designation, at the time of the competition, she was lacking only
5 courses, which she subsequently completed within a very short
period The missing formal education was only a technical default
There was no suggestion that she lacked the necessary skill,
knowledge or ability to competently perform any of the duties of
the posted positions or that obtaining the missing education would
better equip her to perform those dutles The question therefore
lS whether this particular collective agreement permits the
employer to deny a position to an employee who is perfectly able to
carry out the duties and responsibilities of the posted posltion,
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on the sole grounds that she did not fully possess the educational
requirements posted by the employer
Under article 4 3 the obligation on the employer was to give
"primary consideration to qualifications and ability to perform the
required duties " In Re City of Edmonton, (1991 ) 20 LAC (4 rh)
445 (Power) the relevant article of the collective agreement read
In making promotions to vacant positions coming
within the jurisdiction of the Union, the
required knowledge, qualifications and skills
contained in the job posting shall be the primary
considerations and, where two or more applicants
are qualified to fulfill the duties of the
position, seniority shall be the determining
factor
The job posting specified qualifications for the posted
position, including "High School Graduation" The employer awarded
the job to a Mr G, who was considered qualified for the job
although he did not have high school graduation, and was the most
senior among qualified applicants The union grieved, arguing that
without the posted high school graduation Mr G was not qualified
to fulfill the duties of the posted job At p 447 the Board
observed
Except to the extent that the language of a
collective agreement indicates to the contrary,
the jurisprudential trend is towards the view
that the decision as to who is qualified must
relate to the abilities necessary to do the job,
25
because only those factors are relevant To make
a determination otherwise would be to make a
decision which was unreasonable, arbitrary,
discriminatory, or otherwise lacked bona fides
Our collective agreement states that the
primary considerations In deciding who is
qualified are skills, knowledge and
qualifications required by the job posting
The expression "primary considerations"
implies that other considerations may be taken
into account as well, although as mentioned,
"other considerations" taken into account must be
relevant to the abilities necessary to do the
job
In dismissing the grievance, the Board concluded at p 448 as
follows
Particularly bearing In mind the
jurisprudence which focuses its attention on the
relevance of the factors considered by the
selection panel in relation to the abilities
which a suitable candidate must possess to do the
job, we find that a requirement specified in a
City of Edmonton job posting under this
collective agreement may be deemed to have been
met if it is obvious that the candidate possesses
the requisite skills
In Metropolitan General Hospital, (1990) 17 LAC (4 th) 57
(Roberts), the Board held that in the absence of specific authority
In the collective agreement to set educational requirements, the
employer was not entitled to insist on formal educational
requirements as a condition precedent to obtaining a promotion In
that case, the relevant article provided that "Nurses shall be
26
selected for positions on the basis of their skill, ability,
experience and qualifications Where these factors are relatively
equal amongst the nurses considered, seniority shall govern "
The job posting for a vacancy for a part-Time Staff Educator
position required, inter alia, a B Sc N Degree and experience
teaching adult learners The Board was called upon to consider the
power of the employer "to reject even able applicants because they
lack the credentials in terms of academic degrees or specialized
experience called for in the job posting" The employer submitted
that the word "qualified" was to be broadly construed to include
not only ability to do the job, but also possession of more formal
qualifications such as academic credentials or specialized
training, and that it had the unilateral management right to
require formal academic credentials in any job posting
Arbitrator Roberts quoted the following passages from Re St
Catharines General Hospital, (1984) 13 LAC (3 rd) 378 (Teplitsky)
at p 381
A qualified applicant, in my opinion, is one who
is competent to perform the work required by the
classification Although educational
accomplishments may assist in determining whose
qualifications are superior in the context of the
contest which lS established by art 10, that is
quite different from asserting that management
can establish some level of educational
attainment as a condition that must be complied
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with prior to obtaining a promotion If the
employee is qualified in fact (has the know-how,
the ability and any necessary prerequisite
licences) in my respectful opinion, under this
collective agreement he is qualified
On the other hand, where management is afforded
the right by the collective agreement to
establish qualifications for a particular
position, once it is determined that the
qualifications are reasonable, that is, relevant
and made in good faith, then in my respectful
opinion it is not open to an arbitrator to
require management to accept an employee without
such qualifications notwithstanding the employee
may be able to perform the work competently
(Emphasis added)
Arbitrator Roberts stated at pp 64-65
In making these observations, Mr Teplitsky was
referring to a provision with the same wording as
that of art 10 05(c) in the present case He
indicated that unless the management rights
clause or some other provision of the collective
agreement afforded management the right to
establish qualifications for a particular
position, it could not pass over applicants from
the bargaining unit who were, in fact, competent
to perform the work It would not be legitimate
to use educational credentials or formal trainlng
to bar from promotion-~an otherwise competent
member of the bargaining unit
To me, this makes good labour relations sense
Seniority rights are involved here, rights which
often have been said to constitute the soul of a
collective agreement The legitimate expectations
of competent employees to progress in their
careers must be glven full recognition They
should not be easily trammelled At the same
time, the hospital should have recourse to a
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means to establish from time to time, reasonable
and relevant educational requirements for highly
skilled jobs This can be accomplished through
the exercise of a pre-existing management right
to establish qualifications, the negotiation of
such a right where none exists, or even the
negotiation of such a right with respect to
certain specified jobs or classifications
In the present case, the collective agreement
does not grant the hospital a management right to
establish qualifications Nor was any specific
provision of the collective agreement pointed to
which would permit using educational credentials
such as a full or partial B Sc N , or formal
training in adult class-room teaching, as
conditions precedent to promotion to the position
of staff educator
(Emphasis added)
It was held that the employer was not ]ustifled in regarding
the possesslon of the educational credentials as a condition
precedent to promotion
In the present case also, it is beyond doubt that the employer
considered the possession of the-DSW designation by one or more of
the methods set out in the staffing standards to be a condition
precedent to the awarding of a posted RC2 position Employer
counsel argued that the employer set the educational designation in
good faith in the exercise of its management rights, and that since
the designation required was relevant to the posted positi0~ and in
29
accordance with the employer's policy as contained in the Staffing
Standards, it was entitled to do so The Board has no difficulty
accepting as a general rule that the employer has the right to set
educational credentials as qualifications in job postings
However, in applying those qualifications to individual cuses the
employer must comply with the collective agreement The language
in article 4 3 is very clear, and even stronger in the union's
favour than the provisions in the awards referred to above, where
arbitrators have held that quallfications set by the employer must
relate to the skill and ability necessary to do the job Article
4 3 obliges the employer to glve primary consideration to
qualifications and ability to perform the required duties Thus
any qualification or ability required must relate to the required
duties In the absence of explicit authority In the collective
agreement, the employer cannot set an educational credential as an
independent and separate mandatory requirement, unrelated to the
applicant's ability to do the job
The case of Re Toronto Public Library, (1989) 5 LAC (4 th)
192 (Burkett) is instructive, although there what the grievor
lacked was "four years professional library experience" that the
employer had set as a qualification in the job posting The
employer argued that since the union did not allege that the
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30
requirement of the qualification was not arbitrary or
discriminatory, it could not attack its application to an
individual who lacked the qualification In rejecting this
submission, the Board at pp 200-201 stated
If the employer lS correct the concept of
equivalent qualification has no place under this
collective agreement Equivalent qualifications
are those that although not stipulated have equal
significance or value in relation to the job at
issue The object of any job posting (whether or
not under a competition clause) is to identify
the applicants who have the "ability" or are
qualified to perform the job that has been
posted Accepting that the employer (unless the
collective agreement provides otherwise) has the
right to establish relevant qualifications it
would be a strange result indeed, given the
overriding purpose of any job posting procedure,
if an individual who possesses equivalent
qualifications is nevertheless declared
unqualified It is for this reason that we hold
to the view that in the absence of express
language rendering the stated qualifications as
absolutes, with no room for consideration of
whether an applicant possesses equivalent
qualifications, we ought not to infer that the
parties would have intended such a result In
support of this view we quote from the award of
Professor Rayner in Re Sunbeam Home and London 7
District Service Worker-s, supra, as follows [at
p 187]
These authorities support a conclusion
that a board of arbitration may examine
equivalency In terms of formal
educational requirements This
conclusion is also supported by common
sense Formal requirements relate to
the job To conclude that a person who
lacks the precise stated qualifications,
when that person can clearly establish
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true equivalent qualifications, would
not only turn a blind eye to the
realities of the situation but would
also defeat legitimate expectations of
employees without advancing any
legitimate interest of the employer
(Emphasis added)
At p 202, arbitrator Burkett concluded
It lS our view, along with that of arbitrators
Rayner and Adams, that absent express language to
the contrary, an employer, in determining whether
an applicant is, in fact, qualified (that is,
meets the qualifications established by the
employer) , must consider whatever equivalent
qualifications are brought to the competition by
the individual
In the present case also, the employer has not pointed to any
language in the collective agreement authorizing the employer to
set educational qualifications as absolutes There is no
suggestion that the educational credential lnsisted upon by the
employer is a requirement by law, such as a legally required
licence or ticket It was set by the employer relying upon its own
staffing standards See, Re City of Edmonton (supra) Indeed, the
staffing standards themselves expressly contemplate consideration
of equivalency on a case by case basis and the evidence is that the
employer recognized the need to consider "equivalency" and set out
to make inquiries However, its search was restricted to other
32
academic credentials equal to the academic credential it had
established in the posting It failed to give any consideration to
the grievor's experience in the very duties of the job as
equivalency The evidence is absolutely clear that had the
employer done that, it would have concluded that Ms Stephens was
indeed qualified for the posted positions, because she was able to
do all of the duties of the posted position competently, despite
the missing education
The Board therefore concludes that by failing to consider Ms
Stephens' experience as an equivalency to the posted qualifications
the employer contravened article 4 3 In view of this finding it
is unnecessary to deal with the alternative submissions made by the
union
Remedy
As previously noted, had Ms Stephens received the 6 week
--
retraining, the employer certainly would have considered her to be
qualified The evidence is that the duties of Special Needs
position that Ms Stephens had performed for some 8 years, and the
duties of the posted positions were substantially similar Ms
Duquette readily conceded that The employer has also admitted
that Ms Stephens was an excellent employee and highly regarded by
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33
management In that position This is attested to by her
performance appraisals The employer has not in any way questioned
Ms Stephens' ability to competently perform any duty of the posted
position In the circumstances, the Board concludes that Ms
Stephens' experience more than adequately compensated for the
missing education/training and that the employer should have
considered her to be qualified at the time
While Ms Stephens participated in the competition, the
evidence is that she was allowed to do so only pending the
employer's decision on her equivalency She was not informed of
her ranking in the competition The competition file had been
destroyed and there was no evidence as to how Ms Stephens fared
However, it is a necessary inference that once the employer
concluded that Ms Stephens lacked equivalency, she was no longer
in the running no matter how well she had performed in the
competition process, because she was deemed not qualified for the
posted position
The unlon has requested that the Board direct that Ms
Stephens be appointed to a classified RC2 position retroactively
with full compensation The employer submits that the Board lacks
jurisdiction to make such an order In addition, the employer
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34
submits that the Board did not hear any evidence about the relative
qualifications of the other applicants, and that therefore it lS
not ina position to order which of the successful incumbents is to
be displaced by Ms Stephens
In Re Martin, 1582/91, (Dissanayake) the Board concluded that
the employer had discriminated on the basis of handicap contrary to
article A-I by denying a promotion to the grievor because of his
WCB related absences At pp 30-31, the Board wrote
The Board has found a violation of the
collective agreement In the circumstances the
Board derives its remedial authority from section
19 (1) of the Crown Employees Collective
Bargaining Act Under the provision, where the
Board finds a violation, it has a broad
authority, and indeed an obligation, to remedy
that wrong [ In this regard see generally, the
decision of the Divisional Court in Re OPSEU
(Carol Berry at all and the Ministry of Community
and Social Services] The objective in
fashioning a remedy must be to attempt as best as
we can, to put the grlevor in the same position
he would have been in, if not for the employer's
breach Here, a number of facts become
pertinent The employer agreed that all of the
applicants were more or less equal on the basis
of the results of the interview process
Therefore the employer decided to award the
positions solely on the basis of seniority It
is also agreed that the grievor was the most
senior out of the 16 applicants Thus the
grievor would have been made the first job offer
That did not happen only because of the
employer's consideration of the grievor's
absenteeism record The employer considered his
absenteeism record to be so poor that it
35
concluded that the grievor lacked the
qualifications and ability to perform the duties
of the posted position It is clear that this
conclusion in turn was justified only because the
employer considered the grievor's WCB related
absences in breach of the Code and the collective
agreement The employer, even at arbitration,
did not take the position that it would have been
justified in reaching the same conclusion based
on the grievor's non-WCB absences alone Indeed,
considering that in the two years immediately
preceding the competition the grievor had so few
non-WCB related absences, such a conclusion could
not reasonably have been made
The Board ordered, inter alia that the grievor be appointed
to the posted position effective the date the first of the two
vacancies was in fact filled The circumstances here are very
similar The only grounds upon which the employer objected to the
Board's jurisdiction to determine the present grievance, (i e res
judicata as a result of prior settlement) was rejected The Board
has found a violation of the collective agreement Therefore the
Board must answer the question, what would have been the result, if
the employer had not breached the-collective agreement There can
be little doubt on the basis of the evidence that as a highly
regarded employee who had performed the very duties of the posted
position extremely competently for some 8 years, if the employer
had not blocked out work experience as a valid consideration in
assessing equivalency, Ms Stephens would have been awarded one of
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36
the 12 vacant RC2 positions In other words, she was denied a
position only because the employer treated the formal educational
requirement as an absolute pre-condition, and it was not entitled
to do so The inevitable conclusion is that, but for the breach,
Ms Stephens would have been awarded one of the posted positions
In the circumstances, the Board does have the authority to
make Ms Stephens whole by restoring her to the situation she would
have been in, but for the employer's breach The Board orders that
Ms Stephens be appointed to a full-time RC2 position at the SRC,
retroactive to the date appointments were made pursuant to the
posting in question It is not this Board's function to decide how
this appointment is to be done It is up to the employer to decide
how to give effect to the Board's order The grievor lS also
entitled to be compensated for all losses that resulted from the
employer's breach, including interest
----
The Board remains seized in the event the parties have
difficulty in quantifying the compensation owing or in implementing
the terms of this decision
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37
Dated this 16th Day of June 1999 at Hamilton, Ontario
~e/---<--
Nirnal V Dissanayake
Vice Chairperson
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