HomeMy WebLinkAbout1995-0461FLEMING96_06_14
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ONTARIO EMPLOYES DE LA COURONNE
CROWN EMPLOYEES DE L'ONTARIO
/' 1111 GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST, SUITE 2100, TORONTO ON M5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST, BUREAU 2100, TORONTO (ON) M5G 1Z8 FACSIMILE/TELECOPIE (416) 326-1396
GSB # 461/95
OPSEU # 95A704
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTXVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Flemin<J)
Grievor
- and -
The Crown in Right of Ontario
(Ministry of the Solicitor General &
Correctional services)
Employer
BEFORE P Knopf Vice-Chairperson
FOR THE R. Murdock
GRIEVOR Counsel
Ryder, Wright, Blair & Doyle
Barristers & Solicitors
FOR THE M Mously
EMPLOYER Grievance Administration Officer
Ministry of the Solicitor General &
Correctional Services
HEARING February 1, 1996
INTERIM DECISION
In April of 1994 the Grievor was injured at work. As a result she was awarded Workers' Compensation
benefits. She was out of work for a number of months. Thereafter. she was reintegrated into the work force
via a "work strengthening program" devised jointly by the employer and Workers' Compensation. It
involved a gradual increase in her number of hours and days per week over a two month period. She is now
working an eight hour shift. five days a week.
This grievance arises because the grievor was previously working a compressed work week shift with twelve
hour days. She wants to resume that pattern. However. the employer wants to retain her on the eight hour
schedule for the tune being. This means the grievor must work seven days in a row at times to make up her
complete hours. The grievor asserts that she has a contractual right to the compressed work week and that the
employer's denial of that schedule is discrimination on the basis of disability The employer denies
discrimination. Further, the employer raises a preliminary objection to the arbitrability of this grievance,
arguing, that the issue in dispute falls within the exclusive jurisdiction of the Workers' Compensation Act and
its tribunals instead of the Grievance Settlement Board.
The parties agreed that the preliminary jurisdictional issue should be decided before they proceed with any
evidence on the merits. However, for the sole purpose of resolving the preliminary issue, some factual
background was presented through counsel. The relevant facts are set out below'
The Factual Context of the DiSt'ute
The Grievor is a correctional officer She was injured at work in April of 1994 and received Workers'
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Compensation benefits. She was completely off work for a number of months and has subsequently been
awarded a 17% permanent disability pension. Her re-integration to work was arranged by the employer and
Workers' Compensation by a program which placed her in the "main control module." Her work
strengthening began with the grievor returning to work two hours per day This was built up to eight hours
per day, five days a week. Prior to the incident, the grievor had successfully competed for and been placed in
a position entitling her to a twelve hour per day compressed work week. This placement met all of Workers'
Compensation's physical restrictions for the grievor's work including that she not come into direct contact
with inmates.
By March of 1995, the grievor formally asked to resume the twelve hour shift. The employer's response was
"if and when the Workers' Compensation Board deems you fit to resume 'full duties' on a full post rotation
basis, you will resume your previous compressed work schedule." Part of the griever's complaint is that she
is being treated differently than other employees in her situation and that there are other disabled employees
in the module who are working the twelve hour, compressed work week. This would be preferable to the
grievor because it gives her more days off per week.
The grievor continued her attempts to regain the twelve hour shift. She initiated a Workers' Compensation
review to determine the eligibility of some lost time benefits. This review also raised the issue of the
grievor's complaint that the employer was "forcing her to work the eight hour instead of the twelve hour
shift." In September of 1995, the Workers' Compensation Board senior claims adjudicator ruled that the
employer had provided "appropriate alternative employment" and had therefore met its obligations under the
Workers' f'AJmpensation Act. The grievor continued to pursue her attempts to regain the twelve hour shift.
She filed medical evidence in November and December with the Workers' Compensation Board and the
employer That evidence contains her doctor's opinion that the grievor can work "no more than three days on
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and two days off' A further Workers' Compensation review in November 1989 concluded that:
The job offered by the emPoyer is suitable and within Ms. Fleming's restrictions and
capabilities. Given the mllUre of her injury and physical fmdings submitted, Ms. Fleming can work
the shifts as outlined by the employer
The employer has met their obligation under Bill 162 and has provided a comparable job with no
wage loss. Ms. Fleming, under the terms of employment, is required to work the scheduled shifts.....
The employer has outlined scheduling for a twelve hour work week. The fIrst week would be
working sixty hours and rhe second week twenty-four hours. This two week cycle repeats itself.
Given Ms. Fleming's complaints ofoot been able to work more than three days in a row, the
aforementioned shifts woukJ certainly be more fatiguing. Working the shifts for the module position
would certainly be less fatiguing.
If Ms. Fleming worked tlJ:twelve hour shifts the fIrst week of sixty hours, you would have to add the
two hour a day driving. This would make a seventy hour work week.
Based on the above information, it is felt the decision as outlined. in the letter of September 25, 1995,
remains appropriate...
In a nutshell, the Workers' Compeosation continued to uphold the ruling that the employer's offer of the eight
hour shifts was appropriate to meet the requirements of the Workers' Compensation Act.
The employer continued to receive requests from the grievor to be "accommodated" with the twelve hour
compressed work week. The emJ*>yer considered this in light of the doctor's notes which the grievor
provided to the employer and WeBerS' Compensation. On November 16, 1995, the employer responded.
Having regard for the aforesaid docwnents, please be advised the your position in the Main Control
Module on a eight hour scbedule remains available for you to return to. This 'pre-injury job with
accommodation' is within your restrictions as outlined by the Board, and as such meets the
employer's obligation under the Workers' Compensation Act.
The Positions of the Parties
The employer takes the position that the real nature of the grievor's dispute is between the grievor and
Workers' Compensation, not the grievor and the employer The employer asserts that it is acting under the
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direction and in accordance with the requirements of the Workers' Compensation Board in offering the eight
hour shift accommodation to the grievor Accordingly the employer argues that the detennination of whether
the grievor has been offered an appropriate accommodation rests exclusively with the Workers'
Compensation Board. The employer argues that Sections 54 and 69 of the Workers' Compensation Act
create the obligation to re-employ the grievor and gives the Workers' Compensation Board the exclusive
jurisdiction to detennine whether the grievor has been appropriately accommodated. The employer expressed
concern about the possibility that the grievor may be able to pursue a remedy before both the Grievance
Settlement Board and the Workers' Compensation Board and conceivably obtain two conflicting rulings. The
employer asks rhetorically "if the Workers' Compensation Board continues to tell us that the eIght hour
schedule is appropriate, how could a Grievance Settlement Board decision be given any effect if it orders
differently?" It is argued that nothing in the collective agreement or the Labour Relations Act overrides the
exclusive jurisdiction of the Workers' Compensation Board to deal with the issues raised by the grievor's
situation. Therefore, it was argued that the Grievance Settlement Board rule that this grievance is not
arbitrable and dismiss the grievance at this stage.
The Union is relying on Article A of the collective agreement which promises that there shall be no
discrimmation by reason of "handicap" as defined in the Ontario Human Ri~ts Code. Further, the Union
stresses that the grievor has the contractual right to the twelve hour work week. Therefore, it was argued that
by denying the grievor the compressed work week, the employer is discriminating against the grievor under
the collective agreement which gives the Grievance Settlement Board jurisdiction over such a grievance.
Further, the employer's statement that the grievor will be denied the compressed work schedule until she IS fit
to resume "full duties" was said to be evidence of direct discrimination on the part of the employer The
Union acknowledges that the employer's actions may in someway be motivated by the desire to comply with
Workers' Compensation. But, it was argued that where there is an allegation of discrimination, the collective
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agreement allows for a remedy through arbitration. Accordingly, this Board was asked to take jurisdiction
over the matter In addition, it was argued that the employer's obligation under the Workers' Compensation
&t with regard to re-employment expired two years after the incident according to Article 54 (8) (a), which
would bring the parties to one week after the hearing of this matter Therefore, it was said that in terms of a
continuing remedy being available to the grievor, the Grievance Settlement Board is the only appropriate
venue for determination.
Continuing her presentation of the most professional of ways, counsel for the employer. Ms. Murdock
pointed out that the Grievance Settlement Board has issued three decisions in situations similar to this. Two
of the decisions go against the Union's position. They are Lister and Minisuy of Community and Social
Services, GSB File 340/89, (Samuels) and Johnston and Minisuy of Health, GSB File 1225/91, (Tacon). On
the other hand. she offered a decision which was said to be in favour of the Union. Ri ~~lesworth and
Ministry of Transportation, GSB File 637190, (Fisher).
The Decisioo
The collective agreement provides in Article A.
There shall be no discrimination practice by reason of race,
ancestry, place of origin, colour, origin, ciuzenship, creed,
sex, sexual orientation, age, marital status, family status,
or handicap as defmed in Section 10 (1) of the Ontario
Human Rights Code...
The Workers' Compensation Act provides:
Definition "Board" means the Workers' Compensation Board;
("Conumssion") 1982, c. 61, s. 3(1).
Obligation 54 -(1) The employer of a worker who as a result of an injury
to re-employ has been unable to work and who, on the date of the injury, had
been employed continuously for at least one year by the employer
shall offer to re-employ the worker in accordance with this section.
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(4) Upon receiving notice from the Board that a worker is able
to perform the essential duties of the Worker's pre-injury employment,
the employer shall offer to reinstate the worker in the position the worker
held on the date of injury or offer to provide the worker with alternative
employment of a nature and at earnings comparable to the worker's
employment on that date.
Impaired (6) In order to fulfil the employer's obligations under this section, the
Worker employer shall accommodate the work or the workplace to the needs of a
worker who is impaired as a result of the injury to the extent that the
accommodation does not cause the employer undue hardship.
Duration of (8) An employer is obligated under this section until the day that is the
obligation earliest of,
a) two years after the date of the injury to the worker;
b) one year after the date the Board notifies the employer
that the worker is medically able to perform the essentIal dutIes
of the worker's pre-injury employment; and
c) the date the worker reaches sixty-five years of age.
Termination (10) An employer who, having re-employed a worker in accordance with
of re-employment this of re-employment section, tenninates the employment within six months,
is presumed, unless the contrary is shown, not have fulfilled the employer's
oblIgations under this section.
Consequences (13) If the Board finds that an employer has not fulfilled the employer's
of non obligations under this section, the Board may,
compliance
(a) levy a penalty on the employer of a maximum of
the amount of the worker's net average earnings for the year
preceding the injury; and
(b) make payments to the worker for a maximum of one
year as if the worker were entitled to compensation under
section 37, and subsections 37 (2) and (3) apply to the payments
with such modifications as the circumstances may requires.
Conflict with (14) If this section conflicts with a collective agreement that is binding
collective upon the employer and if the obligations of the employer under this section
agreement in respect of a worker afford the worker greater re-employment terms in the
circumstances than the terms available to the worker under the collectIve
agreement, this section prevails over the collective agreement.
Idem (15) Subsection (14) does not operate to displace the seniority
provisions of a collective agreement.
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The case law is of some limited assistance. In the Lis1cI case, the Grievance Settlement Board (GSB), dealt
with a grievance seeking both damages and enforcement of the employer's health and safety obligations under
the collective agreement as a result of a work place accident. The GSB ruled that it had no jurisdiction over
the claim for damages. However, it did take jurisdiction over the question of the enforcement of the health
and safety obligations under the collective agreement. In the Ri~~lesworth case, the grievor had filed a claim
with the Workers' Compensation Board and was awarded short term compensation due to health problems
arising from the use of chemicals at work. The grievor subsequently filed a grievance under the collective
agreement claiming [mandal compensation for past loss of wages and physical hardship The ~ case was
raised by the employer and considered by the Grievance Settlement Board. The Rii~lesworth decision
interpreted the positions of the Workers' Compensation Act differently than were done in Lis.teLand
concluded that Unions and employers are free to negotiate clauses in collecuve agreements which provided
additional [mandal benefits to workers' compensable injuries.
The Johnston case involved a claim for "compensation for excessive workload and overtime." The employer
objected to the GSB taking jurisdiction over the matter In an interim preliminary decision, the GSB ruled
that it is "constrained from awarding damages for work related injuries which are compensable under the
Workers' Compensation Act," However, it also noted "its acceptance of the notion that benefits under the
collective agreement may well be capable of co-existing with compensation under the Workers'
Compensation Act."
These cases are of some assistance but none are completely applicable to the facts at hand. In the grievance
before the Board at this time, there is no claim for additional compensation or damages beyond those
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available under the Workers' Compensation Act. Instead, the sole issue is whether under the present
circumstances, the grievor has a contractual claim, enforceable before the GSB, to be returned to the twelve
hour compressed work week.
It is clear that Workers' Compensation has decided consistently to date, despite several appeals by the
grievor, that the employer's msistence on the eight hour schedule does not offend the Workers' Compensation
&1. It is easy to understand the employer's concern that it may face an arbitral ruling requiring reinstatement
to a twelve hour work week which may be inconsistent with the WCB
Workers' Compensation certainly has the exclusive JurisdictIon to determine whether or not there has been
compliance with the Workers' Compensation Act. Compliance with that Act includes the employers
obligation to re-employ an injured worker to a suitable position which does not cause undue hardship to the
employer According to the Workers' Compensation Board, the employer has complied with the Act.
However, the employer also has an obligation to comply with the collective agreement. This collective
agreement requires the employer not discriminate on the basis of handicap. This latter obligation brings with
it the duty to accommodate someone in the grievor's position. The question as to whether there has been
reasonable accommodation in accordance with the collective agreement is a question that is enforceable and
arbitral before the Grievance Settlement Board. It has jurisdiction to determine whether reasonable
accommodation has been made.
The grievor alleges that she has been discriminated against because there are people in positions and
situations like hers who are not being forced to accept the eight hour work schedule. The grievor seeks the
twelve hour schedule. The question of whether she has been reasonably accommodated is a factual one which
will depend on the evidence of the case. To a large extent, this will be determined by the medical evidence.
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No tribunal will be willing to make a determination on the questIOn of accommodation and/or order the
remedy the grievor is seeking unless medical evidence will support that. But the sole issue before the GSB at
this time is simply whether the GSB has jurisdicaion to hear the claim.
It must be acknowledged that there appears at fll'Sl blush to be some possibility of inconsistent rulings if the
GSB were to take jurisdiction over the accommodation issue, given that the Workers' Compensation has
already ruled that there has been compliance wilb me Workers' Compensation Act. But, it is conceivable that
the employer has complied with the Workers' f'nmpensation Act, yet still be in violation of the collective
agreement. However, the law is capable of.operating on a conunon sense basIS. The Grievance Settlement
Board has jurisdiction over the issues of discrimination and acconunodation. This does not necessarily
interfere with the Workers' Compensation Board's exclusive jurisdiction over whether or not there has been
compliance with that Act. The rights under the collective agreement between these parties are concurrent and
at times greater than the rights available undertbe Workers' Compensation Act. The nghts in the collective
agreement are enforceable through the arbitratioo provisions. The determination of the grievor's individual
case will be based on the facts and medical evidence filed.
Unlike the Li.sta and the Johnson cases, this is not a situation where the griever is seeking compensation for a
work related injury The GSB has no jurisdiction over that type of claim. This is a claim for enforcement of
a collective agreement work schedule and a claim for a remedy (other than compensation) under the parties'
contract. As such, these limited claims fall within the jurisdiction of the GSB. Of course, the chances of
success for the remedy being sought depends entirely upon the strength of evidence available for examination.
Under these circumstances. it is concluded that the Grievance Settlement Board does have Jurisdiction over
the grievance as filed. The matter can proceed to be heard on the merits of the case. As indicated to both
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parties during the course of the preliminary proceedings, it is in both parties' interest that this matter be
determined on the basis of appropriate medical evidence. Therefore, the matter can proceed to a hearing on
its merits. I shall remain seized with the issue.
Due to the sensitive nature of the matter and the desire of both parties to expedite the process, the matter
should be scheduled for conbnuation as soon as can be reasonably accommodated.
DATED at Toronto this 14 dayocJ~ 1996.
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