HomeMy WebLinkAboutP-2015-2909.Strong.17-06-12 Decision
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PSGB#P-2015-2909
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Strong Complainant
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The Crown in Right of Ontario
(Ministry of Children and Youth Services) Employer
BEFORE Marilyn A. Nairn Vice Chair
FOR THE
COMPLAINANT
David Strong
FOR THE EMPLOYER Heather McIvor
Treasury Board Secretariat
Legal Services Branch
Counsel
HEARING May 5, 2017
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Decision
[1] This application alleges that the Crown, represented by the Ministry of Children
and Youth Services (the “Ministry” or the “employer”) failed to accommodate the
complainant in early January 2016. The complainant is a Youth Services Manager
(“YSM”) employed at the Roy McMurtry Youth Centre (“RMYC”), a youth detention and
custody centre.
[2] There was no dispute that the complainant suffers from a disability that triggers
the employer’s duty to accommodate under the terms of the Ontario Human Rights
Code (the “Code”). The parties also agreed that the complainant was, at the relevant
time, subject to workplace restrictions based on that medical need. Those restrictions
are identified in a Fitness for Work Report completed by the complainant’s attending
physician on February 27, 2015. Those same restrictions are also contained in an
Employee Return-To-Work and Employment Accommodation Plan signed by the
complainant on March 31, 2016. The Fitness for Work Report confirms that the
complainant’s disability is a permanent condition and the continuing of the restrictions
over the period in issue confirms that fact.
[3] The complainant’s restrictions required that he:
1) not work night shifts
2) not work days of 14 hours or longer on a consistent basis
3) must have 8-10 hours away from the facility nightly
[4] The OPSEU bargaining unit, representing staff who work in the youth facilities
operated by the Ministry, had been in negotiations with the employer for some time
concerning the renewal of its collective agreement. In early January 2016 the employer
anticipated that bargaining unit members might soon engage in strike action, which
would result in significant staffing disruptions across its facilities. The employer was
engaged in contingency planning to ensure sufficient staffing for the continued safe and
secure care and detention of the youth housed at the facility should a strike occur.
[5] On January 7, 2016 the complainant was asked to meet with Santo Lisi, Deputy
Youth Centre Administrator at RMYC, and Kevin O’Brien, Youth Centre Administrator.
They advised the complainant that his medical restrictions could not be accommodated
without undue hardship during the anticipated strike. A script from the meeting was
provided:
Should there be a labour disruption, managers working in a facility will be required
to work 12 hour shifts, 7 days per week, and remain on-site and on standby during
the remaining 12 hours in each day. As confirmed in your most recent medical
dated February 27, 2015 your medical restrictions prohibit you from working the
required hours and days.
A labour disruption is an exceptional circumstance, where operationally we are not
able to accommodate your restrictions. It is only because of these medical
restrictions which will prevent you from working that you would be eligible to use
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your short term sick credits to cover the duration of the labour disruption. However,
we will not force you to do so; if you would prefer a leave of absence without pay
or to use credits (vacation and/or compensating time) or some combination, please
advise me by Friday, January 8, 2016.
Please know that should there be a significant change in the operational
requirements, whereby we are able to accommodate your restrictions, we will
certainly advise you.
[6] In the result, the complainant was not placed on the assignment roster that
issued that day setting out the staffing coverage for RMYC in the event of a strike.
Following the meeting the complainant reported for work and testified that he felt
embarrassed and humiliated when asked by colleagues why his name was not on the
roster.
[7] The complainant acknowledged that in the meeting he indicated to the employer
that he was prepared to work longer hours in excess of his restrictions. The complainant
also acknowledged that the employer advised him that it would not allow him to work
beyond his medical restrictions. He further acknowledged that Mr. O’Brien may have
said that medical documentation would be required in order to do so.
[8] As it happened, there was a settlement of the relevant OPSEU collective
agreement and no strike occurred. The complainant’s next regularly scheduled shift was
January 9, 2016. He reported for duty without incident.
[9] The complainant testified that at the first meeting to discuss his complaint he was
told that because there was no strike, there was no discrimination, a matter he also
relied on for purposes of this application.
[10] The complainant acknowledged that the existence of a picket line can impede
entry and exit from a facility. When asked in cross-examination, the complainant
testified that the employer was not responsible for adhering to his medical restrictions
so long as he was outside the facility and on the street. He acknowledged that in the
meeting the employer indicated that it would advise him if there was a change in
operational requirements. However the complainant stated that the employer told him
he could not be in the building and no one would know for how long. The complainant
testified that he was willing to breach his medical restrictions but provided no updated
medical supporting any change to his existing restrictions.
[11] Mr. Lisi was also the strike contingency plan lead for the facility. He had also
been involved in responding to prior strikes as a manager both in 1996 and in 2002.
[12] In responding to the 2002 strike by bargaining unit staff, managers were required
to be on site 24/7 and were only allowed to leave for emergencies. Mr. Lisi worked an
average of 18 hours a day during the 2002 strike. Picket line activity would delay the
arrival and departure of staff and although there were protocols for allowing access and
egress, that timing was not always followed. In addition, managers experienced difficulty
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in crossing the picket line and were negatively affected by the nature of comments
made by fellow employees who were on the picket line.
[13] Mr. Lisi described this round of bargaining as more difficult in that no essential
service agreements had been negotiated, leaving the facility to be staffed entirely by
managers during the period of any strike. Those managers would be drawn from other
Ministries and often have little or no experience in operating a youth detention facility. In
prior strikes, essential service agreements between the Crown and OPSEU had
provided that some bargaining unit staff would continue working in order to operate the
facility during the strike. The employer was also concerned that, in the absence of
essential service agreements, there would also be larger numbers of bargaining unit
staff on the picket lines with potential for more disruption and greater risk of incident.
[14] In the event of a strike, the employer expected RMYC managers to remain on
site in order to work the specialized areas in the facility and provide escorts. The work
schedule was expected to be 7 days a week, with a minimum expectation of 12 hours of
work a day and generally more.
[15] Mr. Lisi acknowledged that the complainant would have been an asset to the
facility. The issue for the employer was the inability of the complainant to remain on site,
leading to concerns about providing for his safe entry and exit from the facility. Mr. Lisi
testified that within the first few days of any strike action the employer anticipated being
in a better position to be able to gauge the tactics. Nor was the employer prepared to
alter the complainant’s accommodation plan without further medical documentation. Mr.
Lisi testified that the employer’s main concern was ensuring the complainant’s safety.
[16] Mr. Lisi described the “organized chaos” in the few days leading up to the
anticipated strike. Arrangements were being made for the delivery of refrigerated tractor
trailers to house food during the strike and beds and kits were being bought and
assembled so as to allow managers to remain in the facility for the period of any strike.
Computers were also being set up with software so as to enable managers to
communicate with their families during the period.
[17] The complainant’s regular duties can only be performed within the facility. Mr.
Lisi testified that the only other area where the complainant could have worked would
have been in a Probation Office. Arrangements had been made to close half of those
offices in the event of a strike and operate the remaining half using the pool of
managers. To Mr. Lisi’s knowledge no Probation Office managers were being
redeployed to detention facilities. While Mr. Lisi acknowledged that a YSM would be
qualified to perform some basic duties, he noted that they are not trained to perform the
duties of a probation manager. There was no evidence that the complainant was
qualified to perform Probation Office work.
*
[18] The complainant argued that the employer was required to accommodate his
disability and asserted that the employer was unwilling to do so. He argued that the
discrimination occurred prior to any anticipated strike when the employer informed him
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that he would not be allowed to work during the strike and would be required to use sick
leave or other credits instead, and that he was not thereby included on the assignment
roster. The complainant referred me to a number of excerpts from various employer
communications, including an excerpt from the Ministry of Labour website issued March
2010 concerning the application of the Code and a memo dated March 23, 2016 from
Kevin O’Brien, Youth Centre Administrator, to all managers and staff concerning the
employer’s stated zero tolerance for sexual harassment which states that all “OPS
employees are responsible for respecting the dignity and rights of their co-workers and
the clients they serve”. He also provided a further memo dated February 24, 2016 from
Steve Orsini, Secretary of the Cabinet Office, to all OPS staff announcing that the OPS
had been recognized as one of Canada’s “Best Diversity Employers” for 2016. That
memo highlights the employer’s initiative, among others, in launching a Disability
Accommodation Policy establishing “principles and mandatory regulations for how the
OPS provides timely and effective employment accommodation and accessibility for
employees with disabilities, enabling them to participate equally in the workplace”.
[19] By way of remedy the complainant asked for an order that managers be provided
with sensitivity training, that the managers responsible be recorded on the WDHP
database, and 1.25 million dollars in damages.
*
[20] The employer accepted that it had a duty to accommodate the complainant to the
point of undue hardship. It argued however that any such accommodation had to
honour the complainant’s restrictions and his safety. Providing an accommodation that
discounted or ignored the medical restrictions would be inappropriate, argued the
employer, and would amount to undue hardship. In that regard the employer referred to
the decision in OPSEU (Slack) v. Ontario (Min. of Solicitor General and Correctional
Services), [1998] O.O.H.S.A.D. No. 1(Muir).
[21] The employer argued that the decision to remove the complainant from the
schedule was an interim measure taken so that the employer could assess the unique
pressures of the strike and in turn, its ability to accommodate the complainant. The
employer argued that its interim solution ought not to be held to a standard of
perfection. While the employer acknowledged that this could have led to a delay in
accommodation, it argued that any such delay was necessary in order to ensure safe
and appropriate accommodation based on the complainant’s medical restrictions. In that
regard the employer referred to the decisions in Ontario (MOR) and OPSEU (Alviani),
GSB #2007-3700 decision dated January 21, 2011; Ontario (MOL) and OPSEU
(Fenech), GSB #2006-1704 et al., decision dated July 17, 2012;
[22] The employer argued that it could not ignore medical restrictions or its obligations
under the Occupational Health and Safety Act (“OSHA”). Rather, it argued, the
employer was entitled and required to take into account those obligations under the
OSHA and assess the risk to the complainant in assessing various accommodation
options, referring to the decisions in Slack, supra, and OPSEU v. Ontario (MOL), [1996]
O.O.H.S.A.D. No. 18 (Blair); and U.F.C.W. Local 175 v. Cargill Canada, [2008] 176
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L.A.C. (4th) 306 (Jesin). It was reasonable for the employer to conclude that, given his
particular restrictions, the complainant was at greater risk of injury if he was unable to
cross the picket line, and/or unable to cross it safely, argued the employer.
[23] The employer also referred to the decisions in Greyhound Canada
Transportation Corp. v. A.T.U. Local 1415, (2011) 207 L.A.C. (4th) 192 (Levinson); Brant
(County) v. OPSEU, Local 256, [2012] O.L.A.A. No. 117 (Marcotte); and Automodular
Corp. v. CAW-Canada, Local 1256, [2011] O.L.A.A. No. 189 (Chauvin). It noted that the
decision in Automodular recognized that the duty to accommodate was ongoing yet it
was found that, for the time being, the employer had met its duty to accommodate.
Similarly, the employer argued, if the risks associated with any strike changed, the
complainant could have been brought back to work under safe circumstances that also
met his restrictions.
*
[24] In reply the complainant noted that the employer had talked only about crossing
the picket line and had not talked of him actually doing his job. He noted that he is
always at risk in the facility and that he was not refusing to work.
* * *
[25] The employer did not dispute that, pursuant to the terms of the Ontario Human
Rights Code, it had a duty to accommodate the complainant to the point of undue
hardship. The complainant suffers from a disability and requires accommodation in his
employment. Under usual circumstances, the complainant was being accommodated in
accordance with his restrictions. The issue was whether the complainant’s medical
restrictions could be accommodated at the outset of strike action. As cited in Brant
(County), supra, at paragraph 51, appropriate accommodation to the point of undue
hardship “will depend upon the particular circumstances of the particular situation”.
[26] The fact that the complainant may be exposed to risk in the exercise of his job
functions is not relevant. Apparently the complainant is medically able to perform his
normal job duties with any associated risk, subject to the medical restrictions set out in
paragraph 3 above. Those medical restrictions were not in dispute and one of those
restrictions required that he be away from the facility for at least 8-10 hours nightly.
While the employer may have been able to accommodate the complainant’s restriction
of not working days of 14 hours or longer on a consistent basis during the strike had he
been able to remain in the facility, that third restriction raised the issue of how the
complainant was to be given safe access to and egress from the facility in
circumstances where it was anticipated that a picket line would be established at the
facility and where the employer had advised managers that, in the event of a strike, they
were going to have to remain in the building on a 24/7 basis in order to reasonably
ensure their safety.
[27] The employer was anticipating that, if there was a strike, it might well be a
difficult one. As part of its planning for the strike, whereby it would be required to
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maintain sufficient staff in the facility to safely attend to the youth in detention, the
employer had arranged for refrigerated tractor trailers, stocked with food, to be on site,
reflecting one example of its efforts to reduce the number of occasions whereby anyone
would have to cross a picket line, thereby reducing the risk of picket line incidents.
[28] In order to meet the complainant’s restrictions, the employer would be required to
take all reasonable steps to ensure a safe means whereby the complainant could come
and go from the facility for each shift. Prior to the strike the employer had no reasonable
means of ensuring that it could do so safely in the absence of better information
concerning picket line activity. The employer has obligations to the employee under the
Code and under the OSHA. See, for example, the decision in OPSEU v. Ontario
(Ministry of Labour), supra. The employer is required to consider whether it can safely
accommodate an employee when seeking to meet the employee’s stated restrictions.
While the complainant suggests that the employer ignores safety issues in other
contexts, were the complainant to have suffered injury while accessing or leaving the
facility during a strike, I have no doubt that he would have held the employer
responsible for an asserted safety failure.
[29] An employer also cannot ignore an employee’s medical restrictions when
assessing an appropriate accommodation of a disability. To the contrary. An employer
is required to provide an accommodation that meets those restrictions subject to undue
hardship. Nor can an employer rely on an assertion by an employee that he is prepared
to work beyond his restrictions in the absence of medical documentation supporting a
change to those restrictions. See, for example, the decision in OPSEU v. Ontario
(Ministry of Solicitor General & Correctional Services (Slack), supra. The employer was
required to assess the accommodation having regard to the complainant’s identified
medical restrictions.
[30] There was no evidence reasonably supporting a conclusion that the complainant
could have been accommodated performing work outside the facility. The evidence did
not establish that the complainant was qualified to perform Probation Office work. The
employer also properly noted that, should circumstances change, it would re-visit the
accommodation issue. That is, if strike activity allowed for the safe access to and egress
from the facility, the employer was prepared to accommodate the complainant in those
circumstances. It readily acknowledged that, had the complainant been able to attend
work, such would have been to its benefit. However, the employer was simply waiting in
order to assess the nature of any picket line activity and the associated risks. As noted
at paragraph 243 of the decision in OPSEU v. Ontario (MOL)(Fenech), supra,
“reasonableness of the time taken to accommodate cannot be judged solely by the
length of time”. That assessment also depends on the totality of the circumstances in
each case.
[31] Thus, for the employer to conclude that it could not accommodate the
complainant at the outset of any strike due to the fact that the complainant would be
required to cross a picket line in order to attend and leave work was not unreasonable in
all of the circumstances.
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[32] As it happened, the bargaining was resolved without a strike and the complainant
did not lose any time from work.
[33] The assertion that, at a meeting to discuss the complaint, the employer took the
position that there had been no discrimination because there had been no strike, is not
evidence of discrimination. It was a statement of the employer’s position in respect of
events that had already occurred and about which the complaint had been filed.
[34] Having regard to all of the above, this application is hereby dismissed.
Dated at Toronto, Ontario this 12th day of June 2017.
Marilyn A. Nairn, Vice-Chair