HomeMy WebLinkAbout1995-0577BHATTI98_06_08
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) 326-139<5
GSB #0577/95
OPSEU #95D017
IN THE MA TIER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETILEMENT BOARD
pETWEEN
OPSEU (Bhatti)
Grievor
- and -
The Crown in Right of Ontario
(Mirustry of Housmg)
Employer
BEFORE Owen V Gray Vice-ChaIr
FOR THE E. Holmes
UNION Counsel
Ryder Wright Blair & Doyle
Barristers & SoliCItors
FOR THE D Holmes
EMPLOYER Counsel, Legal Services Branch
Management Board Secretariat
HEARING January 27, April 23 and 24
May 12, September 10 and 11
and November 26, 1997
DECISION
[1] ThIs gnevance concerns a Job competItIOn conducted m early 1995 A set
tlement of thIs gnevor's three pnor gnevances provIded that the employer would
post a vacancy m the classIfied servIce and the gnevor would have the opportu-
mty to compete for the vacancy The gnevor was not the successful candIdate m
the ensumg competItIOn. He alleges that the mdlvlduals mvolved m conductmg
the competItIOn dlscrlmmated agamst hIm because of rus race and place of ongm
and that the competItIOn was not conducted m accordance wIth ArtIcle 4 of the
collectIve agreement.
Background
[2] The gnevor started workmg for the government m 1986 as a temporary
clencal worker He began workmg m the North York office of the Mmlstry of
Housmg's Rent Control Program m August 1988 After a few weeks as a data en
try clerk there, he entered mto what became a senes of unclaSSIfied contracts as
an office support clerk m a posItIOn mvolvmg the handhng of mall. In the sum
mer of 1992, the Mmlstry of Housmg posted a vacancy for a permanent Office
Support Clerk posItIOn m that office The gnevor and others apphed The compe-
tItIOn for that Job was put on hold m August 1992, pendmg clearance of the sur-
plus hst.
[3] In May 1993, a surplus classIfied employee was aSSIgned to the Office
Support Clerk posItIOn that had ongmally been the subJect of the Job postmg m
1992 By letter date June 1, 1993 the gnevor was mformed that the competItIOn
had been cancelled. He filed a gnevance wIth respect to the cancellatIOn.
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[4] ElIzabeth Mason began workmg as the manager m charge of the North
York office m Mayor June of 1993 The grlevor testified that the day she started
she mtroduced herself to others m the office, but not to hIm. When he saId
"hello" to her the next day she dId not reply He was mstructed by hIS supervIsor
that he would not handle filmg for Ms Mason, as he had done for prevIOUS man-
agers When Ms Mason dId speak to hIm, he saId, It was to mform hIm that hIS
eXlstmg contract of employment as an unclassIfied office support clerk m the
North York office was bemg cancelled or would not be renewed He testified that
she offered rum five weeks notice, then changed that to eIght weeks, then demed
havmg offered eIght weeks once a umon representative became mvolved He filed
a further grievance wIth respect to what he alleged was dISCrImmatory treat-
ment on the basIs of hIS colour and natIOnal orlgm. He testified that there was
further dISCrImmatory conduct. He claIms that on one occaSIOn he was gIven an
errand to run out of the office at a time for WhICh an office celebratIOn was
planned On another occaSIOn, he says, Ms Mason mformed everyone but hIm
that they would have a half day off on December 31, 1993, whIle he learned of
the day off from another employee He testified that durmg a dIscussIOn of hIS
grievances, Ms Mason saId to hIm "don't you understand, dear PakI, that you're
gomg to be stuck If you don't drop them." He stated that she had told hIm there
would be no further GO Temp assIgnments If he dId not wIthdraw hIS gnev
ances
[5] After the mall clerk posItIOn was filled by the surplus employee, the
grIevor was gIven a contract to fill a temporary vacancy m an applIcatIOn clerk
posItIOn m the same office That came to an end m March 1994 The gnevor was
then transferred to a posItIOn m Etoblcoke, where he worked for several months
until he was released from employment altogether m about August 1994 He
filed a thIrd grievance wIth respect to hIS release
[6] On December 6, 1994, the date set for the Board's hearmg of the grIevor's
then outstandmg grievances, the partIes dIscussed settlement and eventually
sIgned a wntten agreement ("the Memorandum") that provIded as follows
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1 The MmIstry will, notwIthstandmg any other prOVISIOn of the collective
agreement between OPSEU and the Crown, advertize the classIfied posItion
of Office Support Clerk (classIficatIOn OA3) at 56 Wellesley St. W Toronto
("the posItIOn") under ArtIcle 4 m January 1995, wIth the matter commg to
full closure by March 30, 1995 and the competItIOn will be restncted to
MmIstry of Housmg employees.
2. The grievor will be entItled to apply for the pmntIOn eyen though he IS
not presently employed by the MmIstry, wIth full rIghts of gnevance under
ArtIcle 4 If he IS not successful. The gnevor will also have full recourse, If
appropnate, under all apphcable laws mcludmg the Human RIghts Code
3 Panel members m the competitIOn will be rmpartIal and will choose the
successful candIdate m accordance wIth Article 4. The manager to whom the
posItIOn reports will chaIT the competitIOn panel. No mformatIOn will be
provIded to panel members concemmg the grIevance, human nghts and
WDHP proceedmgs whIch preceded thIS settlement, and such proceedmgs
will form no part of the panel's consIderatIOn.
4. The gnevor and the UnIon hereby release the MmIstry and ItS employees
and agents from any habillty ansmg out of these grIevances and the gnevor's
human rIghts complamt (OHRC File No. TE 000619)
5 The gnevor and the UnIon hereby wIthdraw these grIevances and the
gnevor agrees to wIthdraw hIS human nghts complamt forthwIth.
6. The parties agree that thIS Memorandum will be made and [SIC] Order of
the Board.
The Board then Issued a decIsIOn declarmg that the Memorandum would have
the force and effect of an a ward of the Board
[7] In January 1995, the employer posted a vacancy m a clasSIfied Office
Support Clerk posItIOn at the MmIstry's Rent Control office at 56 Wellesley St
W, m accordance wIth the terms of the Memorandum of Settlement The gnevor
applIed for the posItIOn, as the Memorandum contemplated he could A selectIOn
panel constituted m accordance wIth the Memorandum mtervIewed the gnevor
and ten other candIdates After the competItIOn closed on March 30, 1995, the
gnevor was told that he had not been awarded the posItIOn. The gnevor then
filed the present gnevance
The Job Competition
[8] Braham Kapel was Manager at the Wellesley Street office. He was chaIr
of the competitIOn panel. He and the gnevor knew one another, as Mr Kapel had
been manager of the North York office from the time the gnevor began work
- 4
there untIl about September 1992 The other two members of the competitIOn
panel were Maureen Kramer and NIck Laurella. Ms Kramer was then a Human
Resources AdvIsor wIth the MImstry Mr Laurella was the ActIng Manager of
the North York office NeIther Ms Kramer nor Mr Laurella had had any preVI-
ous dealIngs wIth or concernIng the gnevor
[9] The competitIOn panel IntervIewed gnevor on March 8, 1995 He testIfied
that pnor to that date, probably m February, he saw Mr Kapel at the Scarbor
ough Town Centre They had a conversatIOn. The gnevor stated that durmg thIS
conversatIOn Mr Kapel saId he dId not thInk management would gIve hIm the
pOSItIOn, that they had someone else In mInd for It. He then asked Mr Karpel
what he should do, and Mr Kapel replIed that he should prepare hImself.
[10] Mr Kapel testified that he and the gnevor had encountered one another
at the Kennedy subway statIOn and travelled on the subway together to the
Scarborough Town statIOn, that they conversed, that the upcommg Job competI-
tIOn was mentIOned and that he told the gnevor he should prepare rumself. He
demed havmg saId anythmg to the effect that the outcome was pre-determIned.
[11] The gnevor testified that he telephoned Mr Kapel about a week after that
encounter, and that Mr Kapel agam told hIm that he dId not thmk he would be
selected and that management would make hIS lIfe mIserable and that he should
prepare hImself and come to the mtervIew He stated that after that telephone
conversatIOn he thought there was hope because Mr Kapel was saymg that he
should prepare hImself. He stated that he thought perhaps Mr Kapel dId not
want to say clearly that the Job was hIS
[12] Mr Kapel testified that the only telephone call he receIved from the
gnevor after the encounter m the subway was m the evemng on the day of, and
after, the mtervIew The gnevor asked hIm how he had done He replIed that the
gnevor had done well but told hIm that he could not say anythmg about whether
the gnevor would get the Job
-.:- ~ <~-~
- 5
[13] When the gnevor arnved for rus mtervlew on March 8, 1995, he was gIVen
a Job descnptIOn to read, and then a reference check form to complete The text
of the reference check form authorIzes the Mmlstry to obtam reference mforma-
tIon from persons lIsted, and authorIzes the lIsted persons to prOVIde the mfor-
matIon. Blanks are prOVIded for a lIst of references and for the Job applIcant's
sIgnature The gnevor testIfied that he was gIven no mstructIOn about what to
do wIth thIS form, and was stIll fillmg It out 5 mmutes later when he was called
m to the mtervlew by the female member of the competItIOn panel. He testIfied
m chIef that he mentIOned to her that he had not had enough tIme to fill the
form out, but she dId not reply Durmg cross-exammatIon he was asked whether
he told any panel member that he had not had enough tIme to fill out the form.
He answered that he had thought It would look bad If he asked for more tIme
When he and the female panel member entered the mtervlew room, she mtro-
duced hIm to the other two panel members He says she then stated "we know
your sItuatIOn and Its confidentIal." He took thIS to mean that ElIzabeth Mason
had told them all about hIS sItuatIOn. Ms Kramer demes that she saId what the
gnevor claIms, or anythmg lIke It. Mr Kapel and Mr Laurella both testIfied that
It was not saId m theIr presence
[14] Each candIdate was asked the same 8 questIOns durmg hIS or her mter-
VIew FIve of the questIOns focused on the candIdate's understandmg of and abII
Ity to perform the transactIOnal, day to-day physIcal functIOns of the posItIon.
The first of those five questIOns focused speCIfically on IdentIfymg the candIdate's
past clencal and mall servIce expenence and explammg how It related to the
subject posItIon. The last three questIOns focused on the orgamzatIOnal aspects of
the Job how the candIdate would handle the mterpersonal transactIOns lIkely to
anse m performmg the Job Each member of the competItIOn panel mdepend-
ently assIgned a mark for each answer The panel members dIscussed the marks
afterwards. There was no attempt to reach a concensus on scormg The totals of
the marks assIgned to a candIdate by the panel members were averaged to de-
termme the relatIve rankmg of the candIdate
6 -
[15] Ms Kramer acknowledged m cross-exammatIOn that the Job m questIOn
mvolved performmg routme manual tasks on a faIrly mdependent basIs, and dId
not reqUIre a mgh level of oral commUnICatIOn skIlls The marks Ms Kramer
gave to the gnevor for hIS answers to the mtemew questIOns were generally
lower than the marks he receIved from Mr Kapel and Mr Laurella for the same
questIOns Mr Laurella testified that they dIscussed thIS after the mtemews He
saId that durmg that dIscuSSIOn, Ms Kramer had saId that she felt the gIrevor's
answers had been mcomplete, that he had not made hIS pomts clearly enough to
warrant hIgher scores Mr Laurella testIfied that the gnevor had tended to gIve
short, sometimes even one word, answers to some questIOns He thought that,
knowmg the Job as they dId, he and Mr Kapel had pIcked up on the gnevor's
short answers and had gIven hIm the benefit of the doubt, whIle Ms Kramer,
who was less famIlIar WIth the Job, perhaps mIssed part of the Jargon he used
[16] The top ranked candIdate, Earl AbalaJohn, had a commerce degree and
had qualIfied as a CertIfied PublIc Accountant. He had performed the office sup-
port clerk Job m questIOn as an unclasSIfied employee for a three month perIOd m
late 1990 Smce then he had been workmg m a mgher paId but still unclasSIfied
pOSItIOn as a Rent ReVIew ASSIstant and ApplIcatIOn Analyst m the Rent Control
Program.
[17] The marks Ms Kramer gave to Mr AbalaJohn for hIS answers to the m
tervlew questions were generally equal to or hIgher than the marks he receIved
from Mr Kapel and Mr Laurella for the same questIOns That alone dId not ac
count for hIS final standmg, however Each of the panel members gave hIm a
substantially hIgher mark than he or she gave any other candIdate, mcludmg
the gnevor He clearly appeared from the mtervlew to be the best qualIfied ap-
plIcant.
[18] Reference checks were done for the candIdates WIth the top 7 scores The
panel members dIvIded thIs work among them. Each referee was asked the same
questIOns The object of the exerCIse as far as the competitIOn panel was con
cerned was to determme whether there was anythmg negative that mIght cause
........
- 7 -
them not to offer the candIdate the posItIOn. None of the reference checks re-
sulted m anythmg negative for any candIdate
[19] Ms Kramer revIewed the personnel files for candIdates whose files were
readIly avaIlable m the MmIstry Some files, mcludmg the grIevor's, were not
readIly avaIlable In hIS case, that would have been because he was no longer a
MmIstry employee. Agam, the mtended object of the exerCIse was to determme
whether there was anythmg negative that mIght cause the panel not to offer the
candIdate the pOSItIOn. Ms Kramer's reVIew of the readIly avaIlable personnel
files dId not turn up anythmg negative The candIdates' prevIOus supervIsors
were not contacted unless they had been named on the reference sheets
[20] No marks were assIgned to the results of the reference checks or the re-
sults of the file reVIews The rankmg remamed as It had been, based solely on
the marks assIgned to answers gIven durmg the mtervIews. The top ranked can-
dIdate, Mr AbalaJohn, was offered the pOSItion, and accepted
[21] In June 1996, Mr AbalaJohn was bumped from the subject pOSItion by an
employee WIth 21 years semorIty If the grIevor had been awarded the pOSItion,
he would hkewIse have been bumped. Accordmgly, the umon IS not askmg that
the gnevor be awarded the pOSItIOn, nor that the competitIOn be rerun. The rem-
edy claImed by the umon IS twofold. compensatIOn for the loss of the earnmgs the
grIevor would have receIved m the subject pOSItIOn between April 1995 and June
1996, and rights eqUIvalent to those of an employee surplused as of the date of
the award.
Issues and Argument
[22] In closmg, umon counsel argued that the employer had breached ItS
agreement (m the Memorandum) to conduct the Job competitIOn m accordance
WIth ArtIcle 4 of the collective agreement because
1 It dId not enter mto the Job competitIOn m good faIth, m that the Mm-
IStry was prejudIced agaInst the grIevor, the panel members had Ill-
- 8 -
hented the dIscnmmatory VIews of ElIzabeth Mason and It had been
pre-determmed that the gnevor would not be the successful candIdate,
and,
2 It gave no weIght to whether the candIdates had performed the very
Job m Issue (mdependent of marks assIgned to answers to questIOns
about the Job), nor to theIr supervIsors' appraIsals of theIr Job perform
ance (eIther by contactmg the supervIsors or by assessmg the supervI
sors' performance appraIsals m the candIdates' personnel files), con-
trary to ArtIcle 4 as mterpreted m MacLellan and Degrand~s, 506/81
(Samuels) and other Board decIsIOns
The first ground rested on the gnevor's testImony about Ms Mason's conduct,
events at the North York office after she began workmg there, Mr Kapel's al
leged assertIOns pnor to the mtervIews that the result of the competItIOn was
predetermmed, the remark Ms Kramer was alleged to have made when the
gnevor entered the mtervIew room and the proposItIOn that the panel members
knew more about the settlement and ItS antecedents than was proper
[23] Employer counsel took the posItIOn that the umon's second pomt was a
new claIm not properly before me m thIS proceedmg ThIS was bound up wIth an
assertIOn that the partIes had had an understandmg that the gnevor's rIghts
under the Memorandum to gneve the results of the agreed-upon competItIOn
would only be those that would have been enjoyed by an unclassIfied employee
under the collectIve agreement. Employer counsel asked that I lImIt the hearmg
to the claIms of bad faIth and dIscnmmatIOn or, alternatIvely, permIt her to re-
open her case to mtroduce addItIOnal eVIdence As dIscussed m my decIsIOn of
November 6, 1997 m tills matter, the hearmg was adjourned to permIt employer
counsel to seek mstructIOns and delIver partIculars of the further eVIdence she
wIshed to mtroduce. Pnor to the final day of the hearmg, counsel agreed that the
partIes' argument about the scope of gnevance nghts under the Memorandum
would be addressed on the basIs of eVIdence already before me, and that no fur
ther eVIdence would be mtroduced wIth respect to the ments of the gnevance
- 9 -
[24] Employer counsel argued that apart from the alleged "dear Palti" remark,
the conduct attributed to Ms. Mason was at worst ImpolIte As for the alleged
"dear PakI" remark, counsel submItted that It was not belIevable that Ms Mason
would have met wIth the grIevor alone to dISCUSS hIS grievances on the occaSIOn
when he alleges she made that remark. She submItted that the changes m the
grIevor's Job responsibIlIties followmg Ms Mason's arrival were consIstent WIth
hIS prior dutIes havmg been assIgned to the surplus employee In any event,
whatever may have happened whIle the grIevor was employed m the North York
office, counsel urged me to accept the eVIdence of Mr Kapel and the other mem
bers of the competitIOn panel and find that the competition was conducted m
good faIth and wIthout mfluence by Ms. Mason. She further submItted that m
the context m whIch It was made, the language of the Memorandum only gave
the grIevor the right to grieve about bad faIth or dISCrImmatory conduct, but not
about other flaws of the sort he had complamed of m the alternatIve Reference
was made m that regard to McIntosh, 3027/92 (DIssanayake), and deCISIOns re-
ferred to m It. In the alternative, employer counsel argued that any such flaws
had not affected the outcome of the competitIOn and should not, therefore, be
grounds for any remedy, cItmg Va~llancourt, 1620/87 (WIlson), Peters, 1423/90
(Kaplan) and Sauve, 1695/91 (Gray) In that regard she noted that the employer
IS not oblIged to assIgn marks to the results of such thmgs as reference checks or
the performance appraisals found durmg file reVIews
Decision
[25] The grIevor was by all accounts a good worker He dId a good Job as an Of-
fice Support Clerk m the North York office No doubt he could have done a good
Job as an Office Support Clerk m the downtown office LIke others m the unclas
sIfied servIce, he had contmued to work at temporary Jobs m the hope of some
day wmnmg a claSSIfied posItIOn and the Job security that went wIth claSSIfied
status LIke other good workers m the unclaSSIfied servIce, he saw hIS prospects
of permanent employment fade wIth downsIzmg, along wIth hIS prospects for
contmued temporary employment. The number of qualIfied applIcants vastly ex
- 10
ceeded the number of Job opportumtIes, and those opportumtIes were mcreas-
mgly claImed by permanent, classIfied employees who were bemg dIsplaced from
theIr own Jobs
[26] The gnevor's complamts about hIS alleged mIstreatment m the North
York office were settled, WIthout admISSIOn of wrongdomg, by the WIthdrawal of
those complamts m exchange for the opportumty to compete for a classIfied Of-
fice Support Clerk pOSItIOn m the downtown office But for the settlement, the
gnevor would have had no nght to partICIpate m that competitIOn. Indeed, but
for the settlement the competitIOn probably would not have been held
[27] At the time of the settlement and the subsequent Job postmg, the applIca-
ble collectIve agreement provISIOns were those m the agreement that covered the
perIOd January 1, 1992 to December 31, 1993 Under that collectIve agreement,
unclaSSIfied employees were only covered by some of the prOVISIOns of the Job
postmg artIcle They were covered by ArtIcle 4 1, wruch proVIded for the postmg
of vacanCIes, and Artllce 4 4, whIch prOVIded for time off WIth pay to attend a Job
mtervIew They were not covered by ArtIcle 43 1, wruch prOVIded as follows.
4.3 1 In fillmg a vacancy the Employer shall gIVe prrmary conslderatlOn to
qualIficatIOns and ability to perform the reqUIred dutIes. Where
qualIficatIOns and abIhty are relatIvely equal, length of contmuous
servIce shall be the declClmg factor
The effect of excludmg thIS artIcle from the lIst of artIcles applIcable to unclassI
fied employees was that unclaSSIfied employees dId not have a general nght to
gneve about the results of Job competitIOns McIntosh, supra.
[28] The partIes negotiated the Memorandum m that context. They prOVIded
m paragraph 2 that the gnevor would have "full nghts of gnevance under ArtIcle
4 If he IS not successful" and m paragraph 3 that "Panel members WIll choose
the successful candIdate m accordance WIth ArtIcle 4" In my VIew, those prOVI-
SIOns mcorporated all of the prOVISIOns of ArtIcle 4, mcludmg 4 3 1, mto the set-
tlement as oblIgatIOns of the employer, and gave the umon and the gnevor the
correspondmg nght to enforce those oblIgatIOns. As a result of the settlement,
lI-
the gnevor had the same "full nghts of gnevance under ArtIcle 4" that a claSSI-
fied employee would have had under the collectIve agreement.
[29] I am not persuaded that the Job competitIOn was conducted m bad faIth. I
found all three members of the competitIOn panel entirely credible I accept Mr
Kapel's account of hIS conversatIOns wIth the gnevor concermng the Job competi-
tion. The grlevor's claIm that Mr Kapel saId somethmg to the effect that the out-
come was predetermmed IS mherently Implausible Havmg seen them both tes
tIfy, It seems to me far more lIkely that the gnevor mIsheard or mlsmterpreted
or, perhaps, mIsrepresented what Mr Kapel saId than that Mr Kapel Said what
the gnevor claIms to remember hearmg Indeed, I findmg Mr Kapel's testimony
more belIevable m every mstance where It dIffers from the gnevor's. Whether or
not Ms Mason saId and dId the thmgs that the gnevor attributes to her, I accept
the testimony of the panel members that they were not mfluenced by her many
way Accordmgly, It IS unnecessary for me to decIde whether Ms Mason had a
dlscnmmatory attItude toward the gnevor If she dId, that dId not tamt the de-
liberatIOns of the Job competitIOn panel.
[30] The Settlement provIded m paragraph 3 that
No mformatIon will be provIded to panel members concermng the gnevance,
human nghts and WDHP proceedmgs whIch preceded thIS settlement, and
such proceedmgs WIll form no part of the panel's consIderatIOn.
ImtIally, the umon's argument suggested, as had the thrust of questIOns put to
panel members m cross-exammatIOn, that It would have been Improper for the
panel members to have known anythmg about the terms or even the eXIstence of
the Settlement. Dmon counsel eventually conceded, however, that It would not
have been contrary to paragraph 3 of the Settlement for panel members to have
known of the eXIstence or even the terms of the Settlement I am satisfied that
the panel members other than Mr Kapel knew no more than that the gnevor
was elIgible to compete as a result of the settlement of a gnevance They knew
nothmg about the proceedmgs that preceded the settlement. Mr Kapel had been
summoned as a WItness to the hearmg of December 6, 1994, so he may well have
12
known somethmg about Issues m dIspute m the settled grIevances He was on
hand durmg the negotIatIOn of the Memorandum. He was the manager to whom
the posItIOn described m paragraph 1 of the Settlement would report. The UnIon
and grIevor knew all that when they agreed, m paragraph 3, that the manager to
whom the posItIOn would report would chaIr the panel. I am satIsfied that there
was no breach of the last sentence of paragraph 3 of the Settlement
[31] The reqUIrements of ArtIcle 4 of the collectIve agreement then m effect,
and partIcularly the reqUIrements of ArtIcle 43 1, have been the subject of a
number of deCISIOns by the GrIevance Settlement Board The use of mtervIew re-
sults as the sole baSIS for determmmg "qualIficatIOns and abIlIty to perform the
requIred dutIes" of a pOSItIOn has been deprecated where the deCISIOn makers
have Ignored the employer's corporate knowledge of candIdates' past perform-
ance and of other mdIcIa of qualIficatIOns and abIlIty' see the deCISIOns CIted at
page 19 of Sauve, 1695/91 (Gray) ThIS passage from the deCISIOn m MacLellan
and Degrand~s, 506/81 (Samuels) has often been quoted as settmg out the conse-
quences of the partIes' agreement that the employer must consIder "qualIfica-
tIons and abIlIty to perform the reqUIred dutIes"
The Junsprudence of thIS Board has establIshed vanous cntena by whIch to
Judge a selectIOn process
1 CandIdates must be evaluated on all the relevant quahficatIOns for the Job
as set out m the POSItIon SpecIficatIOn.
2. The vanous methods used to assess the canchdates should address these
relevant quahficatIOns msofar as IS possible For example, mteIVIeW ques.
tIOns and evaluatIOn forms should cover all the quahficatIOns.
3 Irrelevant factors should not be conSIdered.
4. All the members of a selectIOn commIttee should reVIew the personnel files
of all the applIcants.
5 The applIcants' supervIsors should be asked for theIr evaluatIOns of the ap
plIcants.
6. InformatIOn should be accumulated m a systematIC way concernmg all the
applIcants.
See Remark, 149/77, Qmnn, 9178; Hoffman, 22179' Ellsworth et ai., 361180' and
Cross, 339/81.
- 13 -
There IS no suggestIOn here that the panel mIsconceIved the relevant qualIfica-
tIons for the Job, or that eIther theIr mtervlew questIOns or theIr markmg scheme
were mherently mapproprIate The umon argues that because the panel dId not
follow the mstructIOns m paragraphs 4 and 5 of the quote from MacLellan and
Degrand~s, supra, the grIevor should have been the successful candIdate and
should be compensated and gIven other remedIes to put rum m the same POSI-
tIon, so far as It IS now possible, as If he had been awarded the Job
[32] SupervIsors and personnel files can prOVIde relevant mformatIOn about
past performance, partIcularly performance of sImIlar or IdentIcal functIOns The
Board has saId that such mformatIOn should be taken mto account m assessmg
an applIcant's qualIficatIOns and abIlIty to perform the reqUIred dutIes of the Job
A panel that falls to proceed as outlmed m the above-quoted passage from
MacLellan and Degrand~s, may not receIve and conSIder all the relevant mfor-
matIon avaIlable to It WIth respect to qualIficatIOns and abIlIty That may result
m a selectIOn that IS not m accordance WIth the actual qualIficatIOns and abIlItIes
of the candIdates, and such a deCISIOn would be m breach of ArtIcle 4 3 1
[33] Here, the panel solICIted mformatIOn about past relevant Job experIence m
ItS first mtervlew questIOn, mltIally assumed m the applIcant's favour that Job
performance had been good, and then used reference checks and file reVIews to
test that assumptIOn. It dId not examme all the files to whIch WIth more effort It
mIght have had access It dId not questIOn past supervIsors m every case On the
Board's JUrIsprudence, those are methodologIcal weaknesses or "flaws" m the
conduct of the competItIOn. DId those flaws result m a breach of the prOVISIOns of
ArtIcle 4 that the partIes mcorporated by reference mto the Settlement, how
ever? DId they result m a deCISIOn that was not m accordance WIth the relatIve
qualIficatIOns and abIlItIes of the candIdates?
[34] The umon IS askmg for a remedy that IS the analytIC eqUIvalent of
awardmg the grIevor the pOSItIOn m questIOn. The onus IS on the umon to show
not only that the competItIOn was methodologIcally flawed, but also that but for
the IdentIfied flaws the grIevor would have been the successful candIdate D
- 14
Bent, 1733/86 (FIsher), Sauve, supra. The umon argues that past experience
should have been gIven mdependent weIght by assIgmng It pomts, that the
grIevor's 6 years' experience performmg the Job m questIOn should have been
gIven more weIght than Mr AbalaJohn's 3 months' experIence, and that the dIf
ference would have tipped the balance m the grIevor's favour
[35] It IS not at all ObVIOUS that someone who has done thIS partIcular clerical
Job satIsfactonly for 6 years IS more qualIfied or able to perform the necessary
duties than someone who has performed It satIsfactonly for 3 months and then
moved on to work for four years m another pOSItIOn m the office orgamzatIOn
served by the subJect pOSItIOn. There IS no eVIdence or suggestIOn that anythmg
else that could be dIscovered from revIewmg the personnel files or speakmg WIth
ofrmer supervIsors would favour the grIevor over Mr AbalaJohn. Assummg m
the umon's favour the debatable propOSItIOn that a dIstmct score for past experI
ence and performance should have been aSSIgned and added to the mtervIew
scores, I am not persuaded on a balance of probabIlItIes that the grIevor would
have achIeved a hIgher score than Mr AbalaJohn If that had been done WhIle
the grIevor undoubtedly had suffiCIent qualIficatIOns and abIlIty to perform the
Job, the umon has not persuaded me that hIS qualIficatIOns and abIlIty were su
perIor (or even equal) to those of the successful candIdate, Mr AbalaJohn.
[36] For these reasons, thIS grievance IS dIsmIssed.
Dated at Toronto tills 8th day of June, 1998