HomeMy WebLinkAbout1997-2231.ALEXANDER.99-06-14 Decision
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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 SUlTE600, rORONTOONM5G 1Z8 TELEPHONE/TELEPHONE (416) 326-1388
180, RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G rZ8 FACS/MILE/TELECOPIE (416) 326-1396
GSB # 2231/97 0069/98
OPSEU # 98B135, 98B174
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEV ANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees UnIon
(Brent Alexander)
- -- Grievor
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The Crown m RIght of Ontano
(MmIstry of TransportatIOn)
Employer
BEFORE Owen V Gray VIce Chau
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FOR THE Heather E BOWIe
GRIEVOR Counsel
Gowlmgs, BarrIsters & SohcItors
BarrIsters & SohcItors
FOR THE MelIssa Nixon
EMPLOYER Counsel, Legal ServIces Branch
Management Board Secretariat
HEARING Apnl 20 1999
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DECISION
[lJ On February 24 1997, the grIevor filed two grIevances wIth respect to
events that took place m July 1992 The employer objects that they raIse a mat
ter settled m proceedmgs before the Human RIghts CommIssIon and are, many
event, untimely The umon takes the posItion that the documents saId to constI
tute a settlement of a complamt to the Human RIghts CommIssIOn do not bar
these grIevances It demes that the grIevances are untimely but, m the altern a
tIve, asks that the time lImIt for filmg the grIevances be extended ThIS decIsIOn
deals wIth those prelImmary Issues
[2] In 1992 the grIevor was an employee of the Mmlstry of CorrectIOnal Serv
Ices He suffered a workplace mJury that year In settlement of proceedmgs con
cermng hIS rIghts under the then Workers Compensatwn Act the employer
agreed to put hIm m Its redeployment program. C0fiseqllently, he had the oppor
tumty to get prIOrIty mtervlews for vacant posItions before those posItions be
came the subject of Job competitions
[3J In June 1992 the HamIlton DIStrIct office of the Mmlstry of Transporta
tIon wanted to fill two Transport Enforcement Officer 3 posItions They contacted
the Redeployment Umt at Management Board SecretarIat for clearance of a
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competitIOn. The Redeployment Umt asked that the grIevor be mtervlewed for
one of the posItions He was mterVlewed m July by Paul Wake and Bonme Suhr,
who were then DIStrIct Manager and Enforcement Coordmator, respectively, for
the HamIlton DIStrICt. Mterwards, the Redeployment Umt receIVed the followmg
"faxagram" dated July 14,1992 over the sIgnature ofMr Wake
As requested, thIS Mimstry has met wIth Mr Brent Alexander to conSIder hIS
sUltabIlIty for the posltlOn of TransportatlOn Enforcement Officer 3 (T E 0 3)
As IS eVIdent from the attached documentatlOn, Mr Alexander dId qUlte well
m answenng questlOns m the mtervlew process While thIS IS mdlcatlve of hIS
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efforts to prepare for hIS mtervIew we must refuse Mr Alexander as a SUIt
able candIdate for thIS posItIon.
Our reasons are as follows
The knowledge reqUIrements for thIs posItIon are qUIte complex and are
usually attamed through 2 3 years expenence as a TransportatIOn En
forcement officer 2 (T.E.O 2)
The mcumbent must be famIlIar wIth all aspects of on road enforcement
pnor to conductmg the audIt functIOn m order to effectIVely IdentIfv viola
tIons as well as provIde assIstance to the transportatIOn mdustry The
trammg penod to qualIfv as aTE 0 2 IS a one-veal' penod, plus the suc
cessful completIOn of specIfic related trammg courses These courses are
mandatory for both T.E 0.2 and T.E 0 3 posItIOns The knowledge at
tamed through thIS tIme mcludes the theory and practIcal applIcatIOn of
seven dIfferent complex acts and related regulatIOns as well as mInIstry
polIcIes and procedures
Mr Alexander could not perform as a qualIfied officer for at least eIghteen
months These reqUIrements dIsqualIfy Mr Alexander as a potentIal can
dId ate
Our other concern relates to the physIcal reqUIrements of thIs posItIon. Part
of the responsibIlItIes of thIS posItIon IS the actual safety mspectIOn of com
merCIal motor vehIcles ThIs mvolves bendmg, kneelmg and crawlmg under
vehIcles, sometImes on a creeper, and usually m the proxlmltv of other com
merCIal traffic On road enforcement also reqUIres thIs actIvltv, as well as
clImbmg on trucks and mspectmg loads
A check of Mr Alexander s employment file mdlcates hIs neck movement IS
restncted by one-thud and also that he is-to aVOld-a.ny sustamed reachmg be-
yond 12" of hIs body ThIs restnctIOn would clearlv present a problem as an
enforcement officer
[4] About a week after the mterVlew, the gnevor telephoned hIS redeployment
counsellor, Zuzka SladIk. She told hIm he had not been gIVen the posItlon. She
had not yet seen the letter from the MmIstry of Transportatlon, but told hIm she
understood It saId he had not been gIVen the Job because he dId not have the re-
qmred mImstry courses, and because there was a concern about hIS phYSIcal
lImItatlons Some tlme between then and the begmnmg of September, the
gnevor spoke to Ms SladIk agam. By thIS tlme she had obtamed a copy of the
letter, and she read It to hIm. He expressed concern about the reference to hIS
lImItatlons He asked what he could do She also told hIm he could file a gnev
ance She also sald that other posltlOns mIght come up m that dIstnct office She
suggested that If there was a possibIlIty of other posItlOns he mIght not want to
file a gnevance
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[5] In September 1992, after the two telephone conversatIOns wIth Ms SladIk
about the outcome of the mterVlew for the TEO 3 posItIon, the gnevor spoke to
Mr Wake He expressed concern about the references to hIS physIcal lImItatIOns
m the letter Mr Wake told hIm that he had "told them not to put that m the let
ter," or words to that effect. The gnevor testIfied that he understood thIS to mean
that Mr Wake had had nothmg to do wIth the letter Mr Wake told the gnevor
that hIS lImItatIons had had nothmg to do wIth the decIsIOn, that the reason he
dId not get the Job was that he dId not have the reqmsIte mmIstry courses The
gnevor asked Mr Wake whether there would be any further posItIons Mr Wake
replIed that as far as he was aware there would be two TEO 2 posItIons, and that
the postmg for them mIght say that candIdates wIth lesser qualIficatIOns would
be conSIdered.
[6] The gnevor testIfied that he felt wronged at the tIme of hIS conversatIOn
wIth Mr Wake m September 1992 If the mmIstry courses were mdeed cntIcal
for the posItIOn, he could not understand why they would have mtervIewed hIm
for It knowmg, as they dId at the outset, that he dId not have those courses He
knew he could gneve, but chose not to do-so because of the Impact he thought
that mIght have on hIS chances of obtammg one of the other posItIOns that mIght
be commg up
[7] The competItIon for the TEO 3 posItIons was cleared by the Redeployment
Umt and went ahead m late 1992 The posItIons were filled by people who had
the course qualIficatIons the gnevor lacked. The gnevor telephoned Ms Sladik m
December 1999 to ask about the antICIpated further MmIstry of TransportatIon
posItIons She sald there were none He testIfied that m the ensumg conversatIOn
he asked for the first tIme who had SIgned the July letter Ms SladIk told hIm
that Mr Wake had SIgned It
[8] The gnevor testIfied that at thIS pomt he felt Mr Wake had mIsled hIm
He was no longer concerned about the effect of a complamt on hIs chances for
other posItIons He took steps to obtam a copy of Mr Wake's July 1992 letter and
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the questIOn and answer paper he had completed for the mtervIew Havmg ob
tamed those, m about February 1993 he went to the Ontano Human RIghts
CommIsSIOn ("the HRC") to complam that m decIdmg not to gIVe hIm the TEO 3
posItIOn the employer had dIscnmmated agamst hIm because of hIS dIsabIlIty
When asked m cross exammatIOn why he had not filed a gnevance then, he Sald
that when the HRC suggested he should do that he had read the collectIve
agreement, learned of the tIme lImIt for filmg gnevances, and told the HRC that
he could not then file a gnevance
[9J The gnevor's complamt to the HRC was reduced to wntmg and served on
the employer m May 1993 The employer filed a detaIled wntten reply The
thrust of It was that the gnevor had been demed the Job solely because he dId not
have the reqUISIte courses and knowledge It stated that m the ensumg Job com
petItIOn, anyone who dId not have the reqUISIte courses had been screened out
The HRC mvestIgated. By the gnevor's own account, the officer responsIble was
not encouragmg about the prospect that hIs complamt would be pursued by the
CommISSIon. The officer had not found ~eVldence that a TEO posItIon at that level
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had ever been filed by someone who dId not have the reqUIred courses The
gnevor testIfied that the officer told hIm he would try to make a settlement
based on the gnevor s bemg mtervIewed for the next posItIon becommg aVallable
at a lower level that dId not reqUIre the courses
[10J Thereafter, gnevor receIved the followmg letter dated January 27, 1994
from the HRC officer --
Enclosed IS a copy of the letter whIch you requested from the M.T 0 promIS-
mg you an mtervIew and equal treatment should an opemng occur for the po-
SItIOn of Enforcement officer Levell
The ongmal of thIS letter IS bemg maIled to your reSIdence.
ThIS serves to confirm your telephone calls of November 26 and 29 1993,
durmg whIch you adVIsed that you WIshed to WIthdrawn your comp1amt on
the condItIOn that you receIVed a letter from the M.O T as descnbed above
I have been Informed by the staff at the Human Resources Branch at the
M.T 0 that you wIll be notIfied m the event of an openmg for an Enforcement
Officer 1 As well, you are mVIted to call the M.T 0 at (416) 235-5374, from
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hme-to-hme to mqmre as to the possIbIlIhes of any posItIOns becommg aVall
able
Should the M.T 0 ever have an openmg for Enforcement officer 1 and you are
not called, you retam the optIOn of re-opemng your Human RIghts complamt
agamst the M.T 0 and named Respondents
In accordance wIth CommIssIOn polIcy I request that you confirm these m
structIOns to me m wntmg However should I not receIve them wIthm two
calendar weeks of the date of mallmg thIS letter, I WIll act on vour verbal re-
quest and submIt the case-file for closure
Enclosed wIth thIS letter was a letter dated January 25, 1994 addressed to the
gnevor and sIgned by a Human Resources Consultant at the Mmlstry of Trans
portatlOn. That letter sald thIS
I am aware that you preVIously applIed and were mterVlewed for the pOSItIOn
of TransportatIOn Enforcement Officer m 1992 m the HamIlton Dnvers and
VehIcles areaq [SIC] and that you were not chosen as one of the successful
candIdates. I smcerely regret any actIOns taken by the Mimstry whIch left you
WIth the ImpreSSIOn that you dId not receIVe faIr and eqUItable treatment.
At thIS hme. I would lIke to say that you WIll be consIdered for future Trans
portatIOn Enforcement Officer Tramee posIhons. At the present hme there
are no opemngs. However, should an opemng for a TransportatIOn Enforce-
ment Officer 1 level pOSItIOn be advertIsed m the future, and should YOU ap-
ply you WIll be mtervIewed and you WIll be treated on.an equal and faIr basIs
If you have any questIOns regardmg the above pletl.se do not heSItate to call
me at 235 5374
Thank you
[11] The gnevor testIfied that after receIvmg these letters he telephoned the
officer at the HRC and expressed concern about the settlement One of hIS con
cerns, he says, was that whIle the letter from the officer saId that he wDuld be
notIfied of TEO 1 opemngs, the enclose~ letter from the mlmstry dId not say he
would be mformed, but merely that he would be gIVen an mtervlew If he applIed
He acknowledged m cross exammatIon that he dId not ask for a reVIsed letter or
do anythmg else to address hIS concerns He saId that after speakmg to the HRC
officer he thought that was "pomtless "
[12] No TEa 1 pOSItIons became avaIlable between January 1993 and the filIng
of these gnevances
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[13] In December 1996 the mImstry posted vacanCIeS for 6 TEO 3's It decIded
to remove completIOn of specIfic mmIstry courses from the posted mmImum re-
qmrements for the posItIon, m order to encourage more people to apply Of the
successful candIdates, one had not completed the mImstry courses The gnevor
became aware of that m late January or early February 1997 He decIded to file
the two gnevances m questIOn here One complams of Improper fillmg of the
TEO 3 posItIon m 1992, m that the gnevor was demed the posItIOn The other
complams that the mImstry dIscnmmated agamst hIm m that he was demed the
TEO 3 posItIon because of a physIcal dIsabIlIty The gnevor also filed a complamt
under the employer's Workplace DIscnmmatIOn and Harassment PolIcy ("the
WHDP complamt") Those to whom the complamt was assIgned for mvestIga
tIons later completed an mvestIgatIOn and provIded a report, but the result was
not satIsfactory to the gnevor
[14] Ms Suhr IS stIll an employee of the government. Mr Wake IS not, but hIS
whereabouts are known. The file pertammg to theIr mtervIew of the gnevor stIll
eXIsts NeIther of the mdIVIduals who were awarded the TEO 3 posItIons m the
1992 competItIon IS stIll m the posItIon One of the posIti-ons has been filled agam
tWIce smce then, the other has been filed agam once The remedy sought by the
umon If the gnevances succeed on the ments IS an order that the gnevor be put
m one of those TEO 3 posItIons
Argument
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[15] The employer concedes that the tImelmess of these gnevances must be
assessed by reference to the prOVISIOns of the collectIve agreement that was m
force at the tIme of the wrongdomg alleged m the gnevances, not the prOVISIons
of the collectIve agreement m force at the tIme the gnevances were filed Under
the relevant prOVISIons - ArtIcle 27 of the 1992 93 collectIVe agreement - the
tIme for filmg a gnevance runs from the tIme when the gnevor "belIeves he has a
complamt or dIfference" wIth the employer ansmg from the mterpretatIon, ap-
plIcatIOn, admmIstratIOn or alleged vIOlatIon of the collectIve agreement ArtIcle
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27 2 1 proVIdes that an employee who belIeves that he has such a complamt or
dIfference "shall first dISCUSS the complamt or dIfference wIth hIS supervIsor
wIthm twenty (20) days of first becommg aware of the complamt or dIfference" If
the complamt IS not satIsfactonly settled by the superVIsor wIthm 7 days, It may
then be addressed through a process whIch may be begun by filmg a wntten
gnevance wIthm a further 10 days ArtIcle 27 13 provIdes that If a gnevance "IS
not processed wIthm the tIme allowed or has not been processed by the employee
or the Umon wIthm the tIme prescnbed It shall be deemed to have been WIth
drawn."
[16] The employer argues that, on the eVIdence, the gnevor belIeved he had a
complamt concernmg the subject matter of these gnevances m the fall of 1992
when he learned of the contents of the letter receIVed by the Redeployment Umt
or, at worst, the sprmg of 1993 when he filed hIS complamt WIth the HRC It also
submIts that because the gnevor's complamt became the subject of HRC pro-
ceedmgs that were settled, the appropnate forum for entertammg any reopemng
of the complamt IS the HRC
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[17] The umon submIts that the gnevor dId not have the reqUIsIte belIef untIl
he was aware of a factual baSIS for complamt. It argues that he dId not have that
basIs untIl early 1997, when he learned that someone who had not completed the
mmIstry courses had been awarded a TEO 3 pOSItIon. It further argues that the
gnevor dId not have the reqUIsIte belIef when he filed hIS complamt WIth the
HRC, because at that tIme he belIevedJle could not file a gnevance because of
the tIme lImIt m the collectIve agreement. It submIts that the HRC proceedmgs
were not settled m any manner that precludes the gnevor from proceedmg m
thIS forum, notmg that the gnevor dId not SIgn mmutes of settlement or a re-
lease
[18] In theIr submIssIons on tImelmess, the partIes' counsel referred to The
Queen Ln RLght of Ontarw as represented by the Mimstry of Correctwnal SerVLces
v Ontano PublLc SerVLce Employees Unwn et al (1990), 74 0 R (2d) 700 (Ont
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DlV Ct) (denymg an applIcatIOn for JudICIal reVIew of Pwrre, 0492/86 (Venty)),
EllLs, 2473/92 (Low) and Cuthbertson, 0992/93 (Bnggs)
[19] If the gnevances are found to be out of tIme, the umon asks that tne tIme
for filmg them be extended pursuant to subsectIOn 48(16) of the Labour Relatwns
Act, 1995, S 0 1995, c 1 Sch A, whIch applIes to these proceedmgs by VIrtue of
subsectIOn 7(3) of the Crown Employees Collectwe Bargmnmg Act, 1993, S 0
1993 c 38, as amended The umon argues that the subject matter of the gnev
ances - dIscnmmatIon - IS a senous matter and that a gnevance about It
should not be dIsallowed because of delay caused by mIsmformatIOn. The mIsm
formatIOn alleged IS Mr Wake's statement that there would be other postmgs for
whIch the gnevor mIght be a candIdate and the placement counsellor's sugges-
tIon that It would be problematIc If he filed a gnevance The umon acknowledges
that the counsellor cannot be treated as havmg been actmg on behalf of man
agement when she made that suggestIOn. The UnIon submIts that the employer
had not demonstrated actual prejUdICe The mterVIewers and theIr file are stIll
aVaIlable The report of those assIgned to mvestIgate the gnevor's WHUP had
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not IdentIfied any apparent dIfficulty ansmg from the passage of tIme
[20] The employer argues that whIle an allegatIon of dIscnmmatIon IS a sen
ous matter, the gnevor does not allege ongomg duect or systemIc dIscnmmatIOn
The suggestIOn that It would be problematIc If the gnevor filed a gnevance dId
not come from a member of management The alleged mIsmformatIOn dId not
prevent hIm from filIng a complamt w~th the HRe Nothmg but hIS own belIef
that hIS gnevance was out of tIme prevented hIm from filmg a gnevance at that
tIme Nothmg prevented hIm from dIscussmg the matter WIth the umon earlIer
than he ultImately dId m 1997 In all the CIrcumstances, the employer could rea
sonable have assumed long before 1997 that the gnevor had abandoned any
complamt he may have had about the events of July 1992 A delay of thIS magm
tude should only be the subject of relIef m exceptIOnal CIrcumstances WhIle the
mdIvIduals and file are stIll avaIlable, delay of thIS magmtude meVItably affects
memones and the abIlIty to mvestIgate
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Decision
[21] In Cuthbertson, supra, the Board found that the grIevor had had a genu
me belIef that he had no complamt or dIfference wIth the employer until he had
eVIdence to substantiate an allegatIOn that the collective agreement had been
vIolated GIVen the language of Article 27 of the 1992 93 collective agreement
and the mterpretatIon of that language by the Board and the DIVISIOnal Court m
PLerre, supra, the Board found that for that gnevor the time for filmg a grIevance
had not begun to run until he had eVIdence that he thought supported an allega
tIon that the collective agreement had been VIolated. It dId not matter whether
hIS belIef was objectively reasonable, only whether It was genumely held. The
decIsIon m Cuthbertson, does not stand for the propOSItion that for all gnevors
the time for filmg a grIevance under Article 27 of the 1992 93 collective agree-
ment does not begm to run untIl the gnevor belIeves he or she has eVIdence to
substantiate an alleged vIOlatIOn.
[22] I am satisfied that m September 1992 the grIevor belIeved that the em
ployer had acted Improperly m denymg h~m the3EO _ 3 posItion followmg hIS
July 1992 mtervIew and that he could file a grIevance about that under the col
lectIve agreement Accordmgly, I find that he "belIeved" then that he had a
"complamt or dIfference" wIthm the meamng of Article 27 of the collectIVe
agreement m force at the time The time for filmg a gnevance began to run at
that time He deCIded not to file a grIevance Apart from any relevance they
mIght have had on an applIcatIOn to extent the time lImIt, hIS reasons for that
decIsIOn dId not affect the applIcatIOn of the time lImIt speCIfied m the collective
agreement The grIevances are out of time unless the time lImIts are extended. I
turn to the questIOn whether to grant an extenSIOn.
[23] On the gnevor's own eVIdence, by some time m December 1992 he no
longer had any reason not to complam about hIS treatment m July He had been
told m September, and then belIeved, that he could file a grIevance It IS a rea
sonable mference that m December 1992, before he contacted the HRC, he still
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beheved that he could file a gnevance He dId not yet know about any tIme hmlt
for so domg - he says he became aware of that only after he went to the HRC
He chose to complam to the HRC, rather than approach the umon about filmg a
gnevance When the HRC suggested that he file a gnevance, he looked at the
collectIve agreement and concluded that he had mIssed the tIme hmlt for filmg a
gnevance He dId not check hIS mterpretatIOn wIth the umon He sImply offered
the tIme hmIt to the HRC as a reason why It should entertam hIS complamt.
[24] The HRC mvestIgated hlS complamt Eventually, there was the corre
spondence of January 1994 The gnevor IS more reluctant to descnbe that as a
"settlement" now than he was m hlS Apnl 7, 1997 WDHP complamt. In any
event, he dId nothmg to pursue hIS complamt at the HRC or anywhere else for
three years after receIVmg that correspondence Such mactIon strongly supports
the conclusIOn that he abandoned his complamt In answer to that, he would say
that he retamed the nght to reVIVe hlS complamt before the HRC Whether that
IS so or not, he clearly dld nothmg to preserve any nght to pursue hIs complamt
m the gnevance and arbltratIon process under the collectIve agreement He cer
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tamly abandoned hlS complamt m so far as It mIght have been pursued m that
process
[25] The dIscretIon to extend tIme hmlts for filmg a gnevance should not be
exercIsed so as to faCIlItate the reVIval of a gnevance or potentIal gnevance that
has been abandoned, regardless of the length of the delay It may be otherwlse If
the abandonment was mduced by the fraud or deceIt of the OppOSIte party, but
that IS not the case here Apart from the problem of attnbutmg what the coun
sellor saId to management, there lS no basls for concludmg that elther she or Mr
Wake sald anythmg to the gnevor that she or he knew to be untrue at the tIme It
was saId. In any event, the gnevor does not clalm to have rehed on anythmg eI
ther of them sald after December 1992 Indeed, he proceeded thereafter m the
belIef that Mr Wake had been untruthful.
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[26J Even If the delay between January 1994 and February 1997 IS merely
treated as unexplamed and not, as I have done, as affirmatIve eVIdence of aban
donment the CIrcumstances do not JustIfy an extensIOn of the tIme lImIt for filmg
these gnevances
[27] It IS easy to see why what the gnevor learned m early 1997 led hIm to re
gret havmg not pursued the sense of mJustIce he first felt m August 1992
Courses that he had been told were essentIal m 1992 were not treated as essen
tIal m 1996 A vanety of mferences mIght be drawn from that It does not neces
sanly follow, however, that Mr Wake lIed when he SaId he consIdered the
courses essentIal m 1992 nor, mdeed, does It necessanly follow that the employer
breached any legal oblIgatIOn It had to the gnevor at that tIme WhIle the con
duct and outcome of the 1996 competItIOn would undoubtedly be relevant and
figure prommently many hearmg of these gnevances on the ments, the fact that
the gnevor only learned of those matters m 1997 does not explam or excuse the
precedmg delay
[28J The umon argues that delay should "Qe of n()~ons~quence m the exerCIse of
my dIscretIOn to extend the tIme lImIts If the employer cannot demonstrate that
It suffered IdentIfiable prejUdICe as a result of the delay I dealt wIth that argu
ment m my decIsIOn of August 24, 1998 m Gamble, 1635/96, m the context of a
request to extend the tIme lImIt specIfied m a collectIve agreement between the
LCBO and the OLBEU
[19] By Ontano law, every collectIve agreement must provIde for the set
tlement by arbItratlOn of dIsputes about the mterpretatlOn, apphcatlOn, ad
mInIstratlOn or alleged vlOlatlOn of Its proVIslOns. s 48 LRA. The collectIve
agreement may, and usually does, proVIde for a grIevance procedure, under
whIch such dIsputes must be the subject of dIscusslOn wIth a VIew to settle-
ment before they are referred to arbItratlOn. Even when the collectIve agree-
ment contams no mandatory tIme hmIt for glYmg notIce of a dIspute so that It
can be dealt wIth m the resolutlOn process provIded, the claImmg party s un
due delay m glYmg such notIce may lead an arbItrator or arbItratlOn board to
declme to deal wIth the dIspute ThIS mvolves the exerCIse of a dIscretIon
SImIlar to the courts apphcatlOn of the eqUltable doctnne of laches The exer
Clse of that dIscretlOn turns largelv on whether the clalmmg party s delay has
caused prejUdICe to the respondent. see, generallv, Brown and Beatty, Cana
dwn Labour Arbltratwn (3d ed., Canada Law Book) , 2 3210
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[20] Emplovers and trade umons often agree on specIfic mandatory tIme
lImIts for filmg gnevances under theIr collectIve agreements. ThIS reflects
wIdespread understandmg that workplace dIsputes are best addressed as
qUIckly as possible after they anse, and that the employer should be adVIsed
promptly If ItS conduct IS regarded as contrary to the collectIve agreement
(just as an employee or the trade umon should be adVIsed promptlv when the
employer consIders hIS, her or ItS conduct Improper) so that It can govern It
self accordmgly and mmlmlze the consequences for Itself and others should
the complamt be establIshed. Delay m ralsmg complamts for resolutIOn IS an
tIthetIca1 to labour relatIOns expectatIOns and accepted practIces
[21] In some CIrcumstances, the stnct applIcatIOn of a one-sIze-fits all tIme
lImIt would seem unfair and a lImItatIOn proVIsIOn that seemed to cause un
fairness mIght do more harm than good to labour relatIOns Unless the partIes
have expressly excluded ItS applIcatIOn, subsectIOn 48(16) of the Labour Rela
twns Act affords arbItrators the power to extend collectIVe agreement tIme
lImIts m the gnevance process, mcludmg agreed upon tIme lImIts for filmg
gnevances The arbItrator or arbItratIon board may only exerCIse that power
however If satIsfied of two thmgs that there are reasonable grounds for the
extensIOn and that the OpposIte party WIll not be substantIallv prejUdICed by
the extenSIOn.
[22] There are two schools of thought about what may constItute "reason
able grounds" for extenSIOn. Some arbItrators have said that to establIsh "rea
sonable grounds" the umon must establIsh a reasonable explanatIOn for the
defaultmg party's non-complIance wIth the tIme lImIt, that the cause of the
delay was beyond the defaultmg party s control and not due to that party s
faIlure to exerCIse due dIlIgence Re Corporatwn of the CLty of Toronto (Ab
bott), supra, at 127, Re Carborundum Canada Inc., supra, at 439 Others, m
cludmg thIS arbItrator, take the VIew expressed hJLarbItrator Burkett m the
above-quoted passage from Re Becker Milk Co Ltd., that while the reason
ableness of the excuse for the delay IS an Important consIderatIon, the nature
of the gnevance and the length of the delay must also be consIdered m as-
sessmg whether there are reasonable grounds for extenSIOn. Adoptmg that
VIew, Professor SchIff offered an expanded lIst of consIderatIOns m Re Greater
Niagara General HospLtal, supra: the nature of the gnevance, whether the
delay occurred m mltIally launchmg the gnevance or at a later stage, whether
the gnevor was responsible for the delay, the reasons for the delav the length
of the delay and whether the employer could reasonably have assumed the
gnevance had been abandoned.
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[23] However one descnbes the consIderatIOns, on thIS VIew of the "rea
sonable grounds reqUIrement an extensIOn to permIt a gnevance to proceed
concermng a senous and Important matter, such as a dIscharge may not be
precluded when the defaultmg party s excuse for delay IS not Itself reason
able In that event, however, the length of the delay and other delay related
consideratIOns become cntIcal m assessmg whether there are reasonable
grounds for an extenSIOn.
[25] The effect of delay may be that the Opposite party would suffer sub
stantIal prejUdiCe If an extensIOn were granted. PrejUdICe caused by delay IS
sometImes eaSIly identIfied. A Witness who would have been avaIlable for an
ensumg arbitratIOn heanng had the grievance been filed m a tImely way may
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have smce dIed or become mcapacItated or otherwIse unavailable to testIfy
Documents that the respondent would have preserved had It known of a dIs-
pute to WhICh they were relevant may have been destroved m the ordmary
course of busmess, or lost. Other actIOns may have been taken that demon
strablv would not have been taken had the dIspute been asserted m a tImely
way and whIch may now be to the respondent's detnment If the dIspute IS
allowed to proceed. Here there IS no Identrfiable element of specIfic prejUdICe
resultmg from the delay- no demonstrably needed WItness who has dIed or
otherwIse become unavailable m the meantIme, no arguably relevant docu
ment that has been destroyed or lost.
[26] The prejudIce caused by delay may also be more subtle and, bv ItS na
ture, dIfficult to demonstrate. The memones of WItnesses who are strll avaIl
able WIll nevertheless have faded, partrcularly If there has been no notrce that
they may have to testrfy about those memones As a result, theIr testImony
may be or may seem less relIable, and thence less persuaSIve, than It would
have If there had been tImely notrce of the dIspute Those now concerned wIth
the dIspute may not be able to determme what testImony or documents would
have been dIscovered and preserved earlIer had there been trmely notrce of
the dIspute They may not know what statements would have been gIven at
the trme by those WItnesses whom they can now Identrfy, nor what mIght
have been found m documents known to have eXIsted then that have smce
been destroyed. Indeed, they may not now know of or dIscover helpful WIt.
nesses or relevant documents whose eXIstence would have been dIscovered
had trmely assertIOn of the dIspute tnggered an earlIer search for them. It IS
m the nature of these forms of prejudIce that theIr precIse effects and perhaps
even theIr eXIstence m a partrcular case cannot be demonstrated.
[27J It must be remembered that- subsectIOn 48(16) of the LRA Identrfies
the eXIstence of reasonable grounds for an extenslOn IS a questIOn dIstmct
from whether the OpposIte party would suffer substantral prejUdICe If an ex
tensIOn were granted. A defaultmg party who lacks a reasonable excuse for
delay cannot claIm the benefit of the more liberal VIew of the reasonable
grounds test, whIch treats the length of the delay as a dIstmct consIderatIOn
m assessmg reasonable grounds, and then mVIte the arbItrator or arbItratIOn
board to Ignore the delay because It has not resulted m specIfic demonstrable
prejudIce to the OpposIte party s abilrty to defend ItS posItIOn If the grIevance
IS allowed to proceed.
[28] The possibIlrty that delay may have had more subtle prejUdICIal ef
fects, effects that may not be detectable or demonstrable, IS one reason why
the length of the delay IS an appropnate consIderatIOn m assessmg whether
there are reasonable grounds" for an extensIOn, even when the respondent
cannot demonstrate actual prejUdICe Another reason why delay should be
treated as a consIderatIOn mdependent of any demonstrable prejUdICIal effect
IS respect for the bargam the partres have struck. The partres here have
agreed that a dIscharge grIevance must be filed wIthm 10 days They made
theIr mtentIOn that thIS be mandatory clear by theIr further agreement that
gnevances not processed wlthm the trme prescribed are deemed to have been
wIthdrawn. Of course, they did thIS m the shadow of subsectIOn 48(16) of the
LRA, the applrcatIOn of whIch they could have precluded but dId not. There IS
nothmg m the subsectIOn, however, that suggests that arbItrators are to en
tIrely Ignore partIes agreement to specIfic trme lImIts as a consIderatIOn In
exercIsmg the power conferred, or that they are to proceed as though they
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were sImply exerclsmg the dIscretIOn to dIsmIss for delav that they could have
exercIsed If there had been no such agreement.
[29] Even when the OpposIte party cannot demonstrate substantIal conse-
quent prejUdICe delay that IS due to lack of due dIlIgence on the part of the
gnevor or someone actmg on hIS or her behalf can be so extreme that the 1m
portance of a dIscharge grIevance WIll not be suffiCIent baSIS for usmg the
power m subsectIOn 48(16) of the LRA to overnde agreed upon tIme lImIts for
filIng a gnevance
[29] Even If the gnevor here dId not abandon hIS potentIal gnevances, he cer
tamly dId not exerCIse due dIlIgence m consultmg the umon about them or oth
erWlse pursumg them. Even Ignormg the delay before January 1994, the delay
thereafter IS so extreme that the Importance of these gnevances IS not a suffi
clent baSIS for usmg my power under subsectIOn 48(16) of the Labour Relatwns
Act 1995 to overnde the agreed upon tIme lImIts for filmg a gnevance The re
quest that I do so IS therefore demed.
[30] It IS not necessary for me to determme whether the outcome of the
gnevor's 1993 complamt to the HRC constItuted a settlement that would have
precluded hIm from makmg the same allegatIon of dlscnmmatIOn m tImely pro-
ceedmgs before thIS Board. Even If It dId, that "settlement" would probably not
preclude the gnevor's other gnevance m the absence of a broadly worded release
of all clalms ansmg from the demal of the pOSItIon. That other gnevance IS to the
effect that denymg the gnevor the TEa 3 pOSItIon m 1992 was a breach of the
collectIve agreement even If dIscnmmatIOn on a prohIbIted ground played no
part m the deCISIOn Although thIS IS framed m hIS 1997 gnevance as ansmg un
der ArtIcle 6 ("but not exclusIVely") ofthe- 1994-98 collectIve agreement, the claIm
as framed at hearmg IS not that hIS skIll and abIlIty were relatIVely equal to
those of a successful but more Jumor fellow applIcant m a competItIOn. HIS clalm
IS that he ought to have been gIVen the pOSItIon WIthout a competItIOn, on the
baSIS that he had a nght to It If he had the mmlmum qualIficatIons for the Job
ThIS nght IS saId to flow ultImately from an agreement by whIch proceedmgs
under the then Workers Compensatwn Act were settled The Issues before me
were argued on the ImplICIt assumptlOn that such a clalm could be the subject of
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a gnevance under the collectIve agreement In the result, It WIll also be unneces
sary for me to determme whether that assumptIOn IS true
[31] I have found that these gnevances are untImely and I have demed the re-
quest that I extend the tIme for filmg the gnevances m order to render them
tImely Accordmgly, the gnevances are dIsmIssed
Dated at Toronto thIS 14th day of June, 1999
I ~
/
Gray, VIce Charr
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