HomeMy WebLinkAbout1995-1513UNION95_11_10
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, ONTARIO, M5G lZ8 TELEPHONE/TELEPHONE (416) 326-7388
180 RUE DUNDAS OUEST 8UREAU 2100 TORONTO (ONTARIO) M5G lZ8 FACSIMilE /TELEcOPIE (4161326-1396
GSB # 1513/95
OPSEU # 95U104
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
OPSEU (Union Grievance)
Grievor
- and -
The Crown in Right of ontario
(Ministry of Citizenship & Culture)
Employer
BEFORE W Kaplan Vice-Chairperson
FOR THE C Walker
GRIEVOR Job Security Officer
ontario Public Service Employees Union
FOR THE M Wilson
EMPLOYER Counsel
Legal Services Branch
Management Board Secretariat
HEARING October 28, 1995
---
2
Introduction
This case concerns an August 18, 1995 grievance filed by the union arising
out of the closure of the Employment Equity Commission The case
proceeded to a hearing in Toronto, at which time the parties introduced an
agreed statement of fact. It is useful to reproduce that document In Its
entirety
1 The Employment Equity Act ("Act") proclaimed in September 1994,
has as its object the amelioration of conditions in employment for
Aboriginal people, people with disabilities, members of racial minorities
and women in all workplaces in Ontario and the provision of the
opportunity for people in these groups to fulfil their potential in
employment. To accomplish this the Act establishes:
- a process for the development and implementation of an employment
equity plan to remove workplace barriers, initiate positive and
supportive measures and progress towards equality in the workplace for
the above mentioned four beneficiary groups.
. an Employment Equity Commission ("EEC") to administer and enforce
the Act and an Employment Equity Tribunal to adjudicate disputes.
2 The EEC's legislated functions as set out in section 46( 1) of the Act
are.
- further the principles of Employment Equity
- monitor implementation of employment equity and the effectiveness of
the Act
- conduct research and develop policy in relation to employment equity
- assist employers, employees and bargaining agents in complying with
the Act
- educate the public about employment equity
3 The Ontario Public Service as an employer has always had and
continues to have obligations under the Human Rights Code and these
obligations which include:
- investigation of discrimination and harassment complaints
- individual accommodation support for persons with disabilities
- identification and removal of systemic barriers in the workplace
have been carried out by the government in the past and will continue to
be performed by the government in the future.
4 The EEC, a schedule 1 agency of the Ministry of Citizenship, Culture
and Recreation was comprised of'
. The Commissioner who is appointed by Order-in-Council
- Legal Services
- Communications Unit
- An Executive Director
3
5 The Executive Director had three sections reporting to him which are
as follows:
- Client Services
- Compliance*
- Corporate Affairs
*The Compliance section of the EEC was not staffed at the time of the
layoffs due to the fact that the time table set out in the Employment Equity
Act for the preparation of employment equity plans had not become due.
6 On July 19, 1995 the Premier announced that the government will
introduce legislation to repeal the Employment Equity Act.
7 On July 21, 1 995 the Minister of Finance announced a $1 9 billion
spending cut.
8 The Minister announced that due to the fiscal situation the government
had decided to cut funding to a number of government programmes and
projects. The EEC was one such programme and funding was cut back for
the EEC and for the implementation of the Employment Equity Act in the
civil service
9 On the same date, the Minister of Finance also announced that funding
for the EEC will be cut back pending the repeal of the Employment Equity
Act and that planned additional funding to implement employment equity
legislation within the Ontario Public Service would be eliminated. These
measures were to save $8 million this year
10 Specifically, the EEC was cut back by $6 million and the Employment
Equity fund at Management Board Secretariat was cut back by $2 million.
11 On July 25, 1995 the 24 OPSEU bargaining staff at the Commission
were given six months notice under Article 24 1 of the Collective
Agreement due to the government's announced decision to repeal the
Employment Equity Act and the corresponding withdrawal of funding
support to the EEC.
12 All non OPSEU staff have also been provided With notice In accordance
with their entitlements. By the end of January 1996 all staff at the EEC
would have been released.
13 On October 11, 1995 the Minister of Citizenship, Culture and
Recreation tabled legislation referred to as "An Act to repeal job Quota's
and to restore merit-based employment practices in Ontario" This
legislation repealed the Employment Equity Act.
14 This Act also repeals provisions of the Education Act, the Human
Rights Code and the Police Services Act which relate to employment equity
thereby rendering any activities in connection with the functions of
employment equity illegal
15 This Act also decrees as follows:
- All orders and policy directives from the EEC and Employment Equity
-
4
Tribunal are of no force or effect
- All agreements entered into under section 26(2) of the Employment
Equity Act are of no force or effect
- All proceedings before the EEC and the Tribunal are discontinued
- Information collected exclusively for the purposes of the Employment
Equity Act is to be destroyed
19 In a document released on October 11, 1995 the government stated
that the Equal Opportunity plan will not be legislated and will have three
mam components which are:
- support for education and training on equal opportunity
- support for removal and prevention of barriers
- support for partnerships
20 An Equal Opportunity plan will not have the four beneficiary groups
mentioned in the Employment Equity Act and will be for the benefit of all
Ontarians.
21 An Equal Opportunity plan will be a merit based system.
22. An Equal Opportunity plan has not been developed nor approved and
no organizational structure to implement it is contemplated.
24 The Employment Equity Commission is located in leased space on the
10th floor at 77 Bloor St. West.
In addition to this agreed statement of fact, a large number of documents
were introduced on consent.
This dispute rn this case can be SImply stated As a result of the events
outlined above, 24 members of the bargarning unit were declared surplus on
July 25, 1995 Twenty-three of these employees filed indiVidual
grievances, and a union grievance was also filed The parties have agreed to
hold the indiVidual grievances in abeyance pending the determrnatlon of the
union grievance The employees were declared surplus pursuant to Article
24 1 of the Collective Agreement. The union does not take Issue With that.
What the union does take issue With, and underlyrng the union grievance,
was the failure of the employer to abide by Article 26 That proVISion
reads as follows
-
5
26 1 Where a reorganization, or the closure of a facility, or the
divestment, relocation or contracting out of an operation in whole or in
part will result in twenty (20) or more surplus employees in a location,
(a) affected employees shall receive as much notice as possible, but in
any case shall be notified of the imminent reorganization, closure,
relocation or contracting-out not later than nine (9) months in advance
of the proposed reorganization, closure, divestment, relocation or
contracting-out, and
(b) the President of the Union shall be notified of the reorganization,
closure, divestment, relocation or contracting-out at least sixty (60)
days prior to notification to affected employees, and
( c) a committee shall be formed by the parties at the affected location to
provide for consultation and cooperation in order to minimize the adverse
effects upon employees who have been identified as surplus to
requirements.
26.2 The Union may be represented on the committee by a Union staff
representative and up to three (3) employees at the location involved and
the ministry agrees to grant leave with no loss of pay and with no loss of
credits to attend committee meetings.
26 3 With mutual agreement, the Union and the Employer (as
represented by Management Board of Cabinet) shall meet to discuss
system-wide matters concerning closures, divestments, relocations or
contracting-out.
Union Submissions
There were two prerequIsites, In the union's submission, for Article 26 to
apply First, more than twenty employees must be affected Mr Walker
noted that the partIes were agreed that more than twenty employees were
affected in this case Second, a facility must be reorganized or closed, the
union conceding that this case did not involve relocation or contracting out.
In the union's view, both requirements of the provISion had been met, and
that being the case, the union and the employees had been wrongfully
depnved of the benefits of the provision
There was very little doubt, in the union's view, but that the EEC was a
facIlity and that It was being either closed or, In the alternative, being
reorganized as some of its functions were, In the agreed-upon evidence,
arguably being referred to the Human Rights Commission, or would be
-
6
t ,
shortly After reviewing the use of vanous terms In the Collective
Agreement, Mr Walker observed that the term "facility" appears only In
Article 26, and he took the position that it should be given a broad and
purposive meaning Such an interpretation, in the union's submission, was
supported by the redeployment rights of employees of Schedule 1 agencies
considered generally, not to mention by the actual organization of the EEC
which established that It was a self-contained operation with a specific
and wide-ranging statutory mandate, not to mention its own complement of
administrative personnel
Mr Walker noted that Article 26 had been negotiated for a reason, and that
reason, obviously, was to involve the trade union in far-reaching decisions
affecting the employment security of large numbers of employees This
very Involvement, through the notification requirements and committee
work contemplated in the provision, could result in the development of
proactive steps aimed at ameliorating the impact of a closure or
reorganization decision Moreover, these steps, given the nature of the
surplus process, had the potential of affecting other employees as actions
taken with respect to employees surplused as a result of a closure or
reorganization could, and likely would, affect the status of other surplused
public servants This was yet another reason to ensure that employees and
the union obtained the benefits provided for in Article 26, benefits In terms
of notice, Mr Walker pointed out, which were much better than those
provided by Article 24
MOVing precipitously, and denYing employees the benefits of Article 26
could also, in the union's View, result in unfair and unintended consequences
given the way in which government policy is developed and Implemented By
7
way of illustration, Mr Walker noted that at the same time that the EEC
was abolished and the bargaining unit members declared surplus, the
employer was reaffirming Its commitment to some of the goals previously
found within the EEC's statutory mandate In the union's view, there was
some prospect of the job functions of at least some of the grievors, and
perhaps even some of their specific jobs, being performed elsewhere within
the public service, and If this turned out to be the case that would arguably
obviate the need to surplus the positions of all the former EEC employees
The fact of the matter is that Article 26, In the union's submission, was
Intended to provide a mechanism for issues of this kind to be addressed, and
Mr Walker, referring to Whiteside/Stewart 330/92 (Kaplan), argued that It
IS absolutely essential, in cases of this kind, to ensure that the provisions
of Article 26, which provide for a significant degree of union
representation in circumstances of this kind, are given effect. In
conclusion, the union asked me to issue a declaration that Article 26 had
been breached, and to remain seized
Employer Submissions
Employer counsel began her submissions by noting that the government
decided to repeal the Employment Equity Act As a result of that decision,
there was no legislative mandate for the continuation of the EEC's goals,
and no funds to support the achievement of its objectives. Accordingly,
there was no need for the bargaining unit positions at issue In this case and
they were, therefore, abolished This abolition fell squarely, in counsel's
View, within Article 24 1 which referred, among other things, to the
"abolition of a position" or layoffs resulting from a shortage of work or
funds That is all that had taken place in this case and that being so, the
employer argued, there had been no Article 26 breach
-
8
i
In the employer's view, Article 26 applied in cases of mass layoff resulting
from the closure of a facility, and in counsel's submission, the term
"facility" must be given a very narrow reading Counsel pointed out that It
is used in a restrictive away in the Crown Employees Collective Bargaining
Act, (although she conceded that its use there must be read In proper
context, namely with respect to a decision by the Grievance Settlement
Board to reinstate an employee following a finding that he or she has
applied force to a resident in a "facility" or has sexually molested a
resident in a "facility," a term which is then specifically defined)
Attnbuting a restrictive meaning to the term also found support In at least
one dictionary definition of the term which counsel provided Indeed,
counsel argued that the term must be read as meaning a building with
bricks and a geographical address, and only when such a building with a
particular function was closed down would, the employer argued, the
applicable part of Article 26 come Into effect There were also, counsel
observed, some other statutes that used the word "facIlity", one way or
another, and counsel argued that these different uses bolstered her claim
that the term should be restrictively interpreted In fact, counsel argued
that It was doubtful whether the closure of an entire Ministry would
constitute the closure of a "facIlity" for the purposes of applYing Article
26 If Article 26 was Intended to cover every type of closure, counsel
argued, it would have said so Significantly, it did not. While there was one
GSB decision that was arguably related to the issue raised in the Instant
case, that decision, Union Grievance 231 1/94 (Finley) should, counsel
argued be distinguished as the comments therein were obiter and must,
therefore, be accorded little weight.
9
Counsel also made some submissions with respect to the union's alternative
argument, namely that some of the functions of the EEC had been
reorganized and that this provided another basis for Article 26 bemg
mvoked There was, in the employer's view, absolutely no evidence
supporting any assertion that a reorganization had taken place What
eVidence there was, counsel argued, Indicated that the government had
decided to get out of the employment equity business The complete
withdrawal from this field of activity could be seen, counsel suggested, by
the terms of the abolition legislation requiring the destruction of records
created for employment equity purposes While there were references to an
Equal Opportunity Plan, no funds had been allocated to that plan, and no
action had been taken with respect to it. The fact of the matter was that
there had been no "reorganization" of the work, and no such reorganization
was mtended in the foreseeable future
Accordingly, and for the foregoing reasons, counsel, while reiterating the
government's commitment to the enforcement of human rights, asked that
the union grievance be dismissed
Union Reply
In reply, Mr Walker observed that to uphold the employer's limited
definition of the term "facility" would be to effectively gut Article 26 by
limiting Its application to those occasions when a building, used for a
specific governmental purpose was closed down and the purpose or function
eliminated That, he argued, was surely not the intention of the parties, nor
was it a construction that Article 26 could bear He again asked me to
issue a declaration that Article 26 had been breached, and to remain seized
with respect to the implementation of my award
10
Decision
Having carefully considered the eVidence and arguments of the parties, I
have come to the conclusion that the facts agreed to by the parties, and
outlined In this award, constitute the closure of a facility and I therefore
find that the union was wrongfully depnved of the benefits of Article 26
It IS clear that the term "facility" cannot be given the narrow
interpretation suggested by employer counsel Such an interpretation would
render Article 26 meaningless The use of the term "facility" in the Crown
Employees Collective Bargaining Act is extremely specific and limited by
the context of the provision in which that particular definition appears
While employer counsel provided some dictionary definitions of the term,
they are are of limited assistance The Black's Law Dictionary definition,
for example, arguably incorporating bricks and mortar as an Integral
ingredient of the term, but referencing some old Amencan case in support,
is far from persuasive In contrast, the Webster's definition, namely "a
place or office equipped to fulfill a special functIon, a government facility"
comes closer to describing the EEC
There IS little doubt but that the EEC was a government "facIlity" and it
was one designed to fulfill certain government functions To reqUire that a
"facility" be a specific building that must be closed down and the function
terminated would be to ignore the fact that specific government functions
are carried out in a variety of ways and that a decision to terminate a
certain function, or as In thiS case, a facility, will not necessarily, and only
perhaps exceptionally, Involve the actual closure of a building The fact
that the EEC was located in leased premises, as opposed to occupying a
particular building, hardly makes it any less a facility for the purposes of
1 1
applying Article 26
In this case, very simply, the decision was made to close a specific and
Identifiable operation of government - one with its own statute, mandate,
organizational structure, leased premises with a specific geographic
address, lengthy listing in the government directory, albeit under the
Ministry umbrella but with its individuality recognized through an
Introductory descnptlon of Its responsibilities and activities, and status
as a Schedule 1 agency It was known to be fulfilling important and discrete
actIvities on behalf of government and was treated as such It was,
applying simple common sense, a facility, and it was closed down, As a
result, Article 26 should, given the number of employees involved, been
applied While the observations in Union Grievance 231 1/94 (Finley) are
perhaps obiter, they nevertheless support the result reached in this case as
does the consideration, more generally, of the characteristics of Schedule 1
agencies
While the union made some alternative arguments that Article 26 should be
applied because a reorganization had taken place, It is not necessary, haVing
found for the union on its primary submission, to make any findings In this
respect. It may, however, be useful to observe that the evidence is far from
clear that any of the functions formerly carried on by the EEC, while
referred to in the different exhibits, will continue, at least in the near
future, to be carried on by some other body in anything remotely resembling
the duties and planned activities of the EEC
Finally, It IS worth noting that the language of Article 26 IS clear, and
given that language the provision should be given a purposive reading The
12
purpose of the provision is to the involve the trade union when large
numbers (over twenty) of employees of a particular facility will be
affected by a number of events including its closure In the instant case,
such a group of employees was affected by the decIsion of the government,
to quote employer counsel, to get out of the employment equity business It
was within the government's power to make that decision However, It is
obligated, when making decisions of this kind, to abide by the provisions of
Article 26 This provision requires the involvement of the trade union, and
the purpose of that provision is, among other things, to provide the union
with an opportunity to ameliorate the impact of the reorganization or
closure of a facility, or the divestment, relocation or contracting out of an
operation, and to do so dUring the prescribed notice penods set out In the
provision The parties have chosen, in their collective agreement, to create
a process that involves the trade union when certain government decIsions
are taken That process was not followed in thiS case, and I so declare
Accordingly, and for the foregoing reasons, I am issuing a declaration that
Article 26 was breached The effective date of that breach was July 25,
, 995, the date on which the individual grievors were notified that their
positions were being abolished However, and at the request of the parties,
I remain seized with respect to the implementation of any remedy arising
from the breach should the parties prove unable to agree
DATED at Toronto this' Oth day of November' 995
;/;// !~
,
----------------
William Kaplan
Vice-Cha irpe rson