HomeMy WebLinkAbout1998-0936.Sam et al.00-02-24 Decision
o NTARW EMPU) YES DE LA COURONNE
CROW"! EMPLOYEES DE L 'ONTARW
_ _ GRIEVANCE COMMISSION DE
SETTLEMENT REGLEMENT
BOARD DES GRIEFS
180 DUNDAS STREET WEST SUITE 600 TORONTO ON M5G 128 TELEPHONBTELEPHON~ (416) 326-1388
180 RUE DUNDAS OUEST BUREAU 600, TORONTO (ON) M5G 128 FACSIMILBTELECOPIE. (416) 326-1396
GSB # 0936/98 0937/98 0938/98 0939/98 0942/98 0943/98
OLBEU # OLB346/97 OLB319/97 OLB320/97 OLB318/97 OLB295/97 OLB262/97
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BElWEEN
Ontano LIquor Boards Employees Umon
(Sam et al)
Grievor
- and -
The Crown 111 Right of Ontano
(LIquor Control Board of Ontano)
Emplover
BEFORE Nimal V DISSaIlayake Vice Charr
FOR THE Juha Noble
GRIEVOR Counsel
Ontano Liquor Boards Employees Umon
FOR THE Ahson Renton
EMPLOYER Counsel
LIquor Control Board of Ontano
HEARING Januan 5 1999
April 27 28 1999
May 6 7 1999
September 14 15 21 22,28 1999
Noyember 26 1999
Januan 11 12,2000
DECISION
At the commencement of this proceeding I had before me nlne
job competition grlevances arlslng out of a job posting and
competition However, at the hearing on April 27, 1999, I was
advised that grlevors Abdool, Bhatia and Doiron had withdrawn
their grlevances That left for determination, the grlevances
of George Everest, Ted Felora, Barry MacKay, Dave Patterson,
Doug Sam and George Velentzas
Their grlevances relate to a posting (File CR157/97) for
40 vacanCles for Full-Time Customer Service Representative (CSR)
positions in Area A (Toronto) It lS common ground that these
vacanCles arose as a result of the application of a Letter of
Agreement on Permanent Vacancy Review, which inter alia,
required the declaration of a vacancy and posting, where a
casual employee had worked 1,700 hours or more In a retail
store The posting In question was dated May 26, 1997 and had
a closing date of June 16, 1997
The preamble to the posting reads
Under the general supervlslon of the Manager, you
will provide prompt, courteous and knowledgeable
customer serVlce In accordance with the Customer
Service Standards of Excellence, participate In and
comply with corporate initiatives as made mandatory
(e g PKCC levels, SMAART) , keep abreast of and
3
participate In timely execution of Ready for Business
and Retailer of Choice Standards, recelve, handle,
store and rotate stock In orderly, systematic and
safe manner, adhere to Occupational Health and
Safety, WCB and WHMIS guidelines, support and
contribute to a harmonious and productive work
environment, follow security procedures of LCBO
funds, stock and properties, exhibit ability to
operate computerized systems and interpret financial
information, promptly and accurately complete all
store reports and records, be prepared to work
extended hours based on operational requirements
The following was listed under .Qualifications.
Position requlres tact, diplomacy, good oral and
written communication skills, ability to maintain and
contribute to positive interpersonal relations with
customers, LCBO employees and trained
representatives, mathematical, clerical and
accounting skills, ability to operate computerized
terminals (office or cash register terminals) , good
knowledge of cashiering and security procedures,
initiative and reI i ab i lit Y , ability to work with
mlnlmum superVlSlon and routine checks, ability to
meet the essential physical requirements of the job,
general knowledge of products and services offered by
the outlet and by the LCBO which may include
servlclng of licensees and agencles In a socially
responsible manner You should also demonstrate an
awareness of and support the LCBO strategies
including Customer Service, Excellence, t hat .S The
Sprit, and Ready For Business Standards You will
have successfully completed product Knowledge Level
II and working towards Product Knowledge Level 3
The posting also stated
PLEASE NOTE
- The area of search will be the geographical
posting area
- A Q-35 Form must be submitted with your store
number or department number Employee
4
identification number and the appropriate
posting number accurately recorded
- Qualified PPT candidates will be selected In
accordance with the procedures under Article
21 of the Collective Agreement
- Candidates from Casual status will only be
considered when there are no qualified
Permanent Part-Time Employees
- Casual candidates will be selected In
accordance with the procedures under Article
31 4 of the Collective Agreement
- Candidates must meet the following mlnlmum
criteria In order to be considered a) Past
satisfactory work performance, b)
Satisfactory discipline and attendance
records, c) French language serVlces
requirements where applicable
- Casual candidate qualifications will be
determined through a process consisting of a
scored interview and scored past performance
appraisals
- A circular will be issued announclng the
successful candidate
The posting was open to all permanent part-time and casual
employees of the LCBO-s store system in Area A Three permanent
part-time employees were offered positions In priority as
contemplated by the collective agreement, leaving 37 vacanCles
to be filled through a competition among casual employees
Approximately 230 casual employees applied As required In the
posting, a form known as the -Q-35" was used to make application
This form, titled -Application for Posted Vacancy- lS extremely
5
brief and has space only for the employee name, date, present
position, store and Department, status (Permanent Full-Time,
permanent part-Time, or casual) and Social Insurance Number, and
lS to be signed by the applicant
Once the posting closed, the Human Resources Dept screened
the applicants for interviews One applicant was denied an
interview because he had not completed the pre-requisite -Product
Knowledge I I- He did not grleve Several applicants were
denied interviews on the basis of their active discipline on
file Two of them grieved, namely grlevors Patterson and
Velentzas The employer selected 59 applicants to proceed to
the competition, which consisted of a scored oral interview and
a scorlng of the 2 most recent performance appraisals Through
this process the 37 positions were filled Grievors Everest,
Felora, Mackay and Sam participated In the competition but were
not successful They had more seniority than some of the
successful candidates, and grieved alleging that the employer
had contravened the collective agreement
The successful candidates (incumbents) were provided notice
of this proceeding as required by law Some attended hearings
more regularly than others Some did not attend at all The
6
Board made it clear that each incumbent was entitled to fully
participate In the proceedings as a party, with or without
counsel Of those attending, some participated actively, while
others were mere observers None of the incumbents testified
and none called any evidence
The governlng provlslon In the collective agreement lS
article 31 4 (b) which reads
The Employer agrees to glve consideration to the
qualifications and ability of casuals for permanent
full-time vacanCles at the entry level In their
geographical area, provided that no permanent part-
time employees have applied Where qualifications
and ability are relatively equal, seniority shall be
the determining factor
The union made a two pronged argument First, it pointed
out that there was substantial similarity between the duties and
responsibilities of a casual CSR and those of a full-time CSR
All of the applicants had performed the duties of a casual CSR
In the circumstances, it was argued that as long as the
applicants passed the initial screenlng (which recognlses the
absence of any maJor concern and the presence of all pre-
requisites) they should be all deemed to be qualified and
relatively equal In qualifications and ability That being so,
the argument went, there was no justification or need for any
further interview process, and the positions should have been
7
awarded on the basis of seniority alone On this basis, the
unlon urged that the Board order that the positions be awarded
by order of seniority, to those applicants who passed, or should
have passed, the screenlng
In the alternative, the unlon takes the position that the
competition process conducted by the employer was fundamentally
flawed In a number of ways and did not comply with article
31 4 (b) The unlon contended that the results of such a flawed
process ought not be allowed to stand, and sought an order that
the competition be re-run
Initially the union had taken the position that in the past
the employer had followed a practice of awarding full-time CSR
positions to casual employee applicants on the basis of
seniority alone, and that it was estopped from changing that
practice for this posting However, during the course of the
hearing, unlon counsel advised the Board that the unlon would
not be pursuing that argument, without prejudice to its right to
ralse it in other cases
Article 31 4 (b) lS what lS commonly described as a
-relative equal i ty- clause, as opposed to a -threshold abili ty-
8
clause In the latter t yp e , once applicants are found to meet
a threshold or mlnlmum level of ability and qualifications,
seniority determines who among them are entitled to the
available vacanCles On the other hand, In the face of a
relative equality clause, the employer must not only determine
whether the applicants meet a threshold standard, but it must
also determine whether the applicants are relatively equal In
ability and qualification This determination includes an
. . to whether there substantial and demonstrable
lnqulry as lS a
difference In qualifications Re Vaillancourt, 1120/87
(Wilson) Seniority becomes a determinative factor only among
those applicants found to be relatively equal The screenlng
process undertaken by the employer was intended initially to
weed out those applicants who did not meet the threshold level
of ability and qualifications Under a relative equality
clause, once a pool of minimally qualified applicants lS
established through the screenlng process, the employer next has
to assess the relative abilities and qualifications among those
applicants
The union-s argument lS that the employer should have gone
from a determination of threshold ab i 1 i t Y , to an awarding of
positions on the basis of seniority That would be to treat
9
article 31 4 (b) as a threshold ability clause, which it lS not
Conducting interviews lS one method open to the employer to
gather the information about the applicants. abilities and
qualifications for purposes of determining relative equality
Review of the applicants. personnel files, performance
appraisals, resumes and references and consulting their
superVlsors, are some of the other important sources of such
information Provided they are conducted In a fair and
reasonable manner to elicit relevant information, interviews are
a useful and a legitimate tool available to an employer In
determining relative equality
The evidence does support the union.s assertion that there
are substantial similarities between the full-time and casual
CSR duties and that all of the applicants had worked as casual
CSRs However, the evidence also indicates that some applicants
had been exposed to a broader range of CSR duties than others
Some had worked as CSR for a longer period than others, and had
greater experlence Therefore, the employer was entitled by
article 31 4(b) to determine who among the applicants were
relatively equal In qualifications and abi I i ty, and who were
not The employer was not precluded from resorting to oral
10
interviews as one method of gathering information required to
make that determination
For the foregoing reasons, the Board finds no merit in the
union.s position that the employer should have awarded the
positions to the applicants who passed the screenlng, on the
basis of their seniority That would be tantamount to . .
19norlng
the relative equality language In article 31 4(b) See, Re
Netta et aI, 1404/97 etc (Mi kus)
Therefore the Board turns to consider the union.s alternate
argument that the competition process conducted was so
fundamentally flawed, that the results generated thereby should
not be allowed to stand
The competition process
The evidence lS that the employer had concerns that job
postings involving promotion of casual C S R .S to full-time CSR
positions, were being conducted inconsistently In the varlOUS
areas and reglons within the prOVlnce With the inclusion of
the Permanent Vacancy Review Letter of Understanding in the 1996
collective agreement, it was anticipated that a substantial
number of such vacancies would have to be posted Therefore, the
11
employer devised a new recruitment process to take effect In 1997
for the filling of vacancies that result from the application of
the letter to casual hours worked In 1996 The basic goal was
to have a process that would be applied consistently In all
locations within the provlnce A number of documents were
prepared setting out the new process Mr Wayne Zachar,
Director of Employee Relations, was closely involved In the
creation of this new recruitment process He testified about how
the new competition process was intended to be implemented
The basic steps In the Process are set out In a document
titled .Customer Representative Recruitment Process. , as follows
STEP 1 Post Vacancy
STEP 2 Screening Process
Eligible candidates. discipline,
attendance and performance appraisal
records are reviewed Must have
satisfactory discipline, attendance and
performance appraisal or are screened
out
STEP 3 Interview process
Determine the number of employees to be
interviewed by ranking In seniority
order and uSlng between a 3-1 and 2-1
ratio Look for gaps In seniority,
where possible
Interview using bank of CSR questions
12
Weighting of performance appraisal will
be 40
Weighting of interview will be 60
STEP 4 Determination of Successful Candidate(s)
Overall pass mark will be 50
Relatively equal spread will be 20
Rank in order of overall score
Promotions are granted to the senlor
employees within the 20 spread
STEP 5 Not Enough Successful Candidates
Continue down the list and interview
until all potential vacanCles are
filled
Do not advise candidates of outcome
until ALL interviews are completed as
the successful candidates may change
STEP 6 Prepare Applicable Documentation
to Process promotions/Appointments
With regard to Step 2, Mr Zachar testified that
-satisfactory discipline- meant that if there was active
discipline on an applicant-s personnel file, management must be
satisfied that it was not serlOUS enough to disqualify the
applicant, and that each case had to be decided on its own
merits Mr Zachar testified that the employer decided to reVlew
13
attendance records because regular attendance was a necessary
qualification for a full time CSR Similarly a reVlew of
performance appraisals was a useful tool . .
seen as In assesslng an
appl ican t-s qualifications for the vacant position It was
decided that only the two most recent appraisals on file would
be considered because that would provide -a more balanced picture
of his performance - The two appraisals were to be scored out of
a maXlmum score of 25 points The two appraisals were weighted
at 40 percent, of the total score for the competition, while the
balance 60 percent was allotted to the oral interview process
Recognizing that different appraisal formats were used to
evaluate casual employees, the employer devised two rating
scales Where an appraisal form had evaluated areas of
competency with a five point rating scale, points were assigned
as follows
1 -Outstanding- = 1
2 75
3 -Meets Requirements- 5
4 25
5 -Change Required- 0
Where a form evaluated areas of competency with a four
point rating scale, points were assigned as follows
14
1 -More than meets requirements- 1
2 -Meets Requirements- = 75
3 -Development Required- 25
4 -Unsatisfactory- = 0
Areas of competency were allotted different weights,
depending on the employer-s Vlew of what areas were more
important For example, -cus tomer service- was weighted higher
than -appearance- or -safety and protection of LCBO assets-
Mr Zachar testified that In revlewlng appraisals, the
process did not take into account anything other than the scores
assigned by the appralser to the listed areas of competency
Comments written out by the appralser In the comments section of
the appraisal were not to be given any consideration because, In
his Vlew, such comments -merely substantiated the scores given-
Where a -N / A- (not applicable) was marked for an area, the
applicant got a zero for that because the N/A indicated that the
employee had not performed that particular function or skill
When asked why applicants- resumes were not reviewed, Mr Zachar
replied, -1 twas felt that for this type of competition it wasn-t
appropriate - that it will glve an unfair advantage to persons
more skilled in preparation of resumes -
15
With regard to step 3 In the process, the interview, Mr
Zachar testified that 3 to 1 and 2 to 1 ratios were used to limit
the number of initial interviews, because it was not useful or
practical to interview everyone who applied A bank of questions
was put together for use in these interviews, although Mr Zachar
did not know who prepared those questions He stated that the
typical interview panel was to consist of two members from
operational management and one from the Human Resources Dept
Mr Zachar was involved in the decision to asslgn 60 percent of
points in the competition to the interview and 40 percent to the
two performance appraisals The percentages were assigned based
on the management .S Vlew of the relative value of an interview
and a review of performance appraisals The minimum percentage
required to be qualified was set very low at 50 because
management recognized that some employees may not interview well
and that appraisals may be subjective depending on the
relationship between the employee and the superVlsor doing the
apprisal
Referring to step 4, Mr Zachar explained how the 20
percent spread for relative equality was to be applied Once the
highest scorer In the competition was determined, the scores of
16
every applicant who had more seniority than the highest scorer
were to be compared to determine whether their scores came within
20 percent of the highest score All applicants within 20
percent of the highest scorer are awarded positions by seniority
Next, if vacancies still remain after this process, the highest
scorer lS awarded a position
At this point the highest scorer goes out of the picture
The next step lS to determine who the second highest scorer was,
and he now becomes the comparator All applicants not yet
awarded positions, and who are more senlor to that second highest
scorer, are compared Those scoring within 20 percent of that
second highest scorer are awarded positions by seniority If at
the end of this process vacancies still exist, the second highest
scorer will then be awarded a position Next the third highest
scorer, becomes the new comparator and this process lS carried
out until all of the available vacanCles are filled If at the
completion of this process, not enough qualified applicants are
found to fill the available vacancies, additional interviews were
to be scheduled under step 5
The alleqed flaws In the process
The union submitted that the employer failed to gather all
relevant information required to properly assess the applicantes
17
abilities and qualifications Instead, the employer relied
solely on interview scores and a numerical conversion of just 2
performance appraisals for each applicant According to the
union there was much more useful and relevant information easily
available to the employer which it ignored
The unlon took lssue with the fact that the employer only
considered the last two performance appraisals on file The
employees. personnel files contained much more information, which
was directly relevant to ability and qualifications As
examples, the union pointed out that the grlevors had more than
just two appraisals on file Some of the appraisals not
considered, had very high ratings as well as very complementary
comments by the appralser, which reflected positively on ability
and qualifications Even In the 2 appraisals reviewed, the
employer ignored comments made by the supervlsors The personnel
file of one grlevor contained a letter of commendation written
by the District Manager This received no consideration In
addition, the employer did not reVlew any resumes
The unlon pointed out to the evidence that the employer
policy required that performance appraisals be conducted on each
employee annually This had not been done As a result, some
18
of the applicants had appraisals on file coverlng 1996 and 1997
Others did not Their two most recent appraisals on file
included 1994, 1993 or even older appraisals As a result some
had their performance some years ago scored, while others had
their recent performance scored The time period assessed for
varlOUS employees was different The union pointed out that one
incumbent, D Leet, was assessed on the basis of his 1991 and
1992 appraisals This inconsistency resulted from the employer-s
failure to comply with its own policy which required annual
appraisals
The unlon further took the position that the weighting for
the review of the 2 appraisals was inappropriate, and that the
resulting scores failed to reflect the level of performance
indicated In the appraisals The weighting resulted In
unreasonably low marks For example, where an employee received
a score of 3 for an area of competence In a 5 point grid,
according to the legend In the appraisal form itself, that
indicated that the employee was .sa ti s factory. or .met
requiremen ts. In that category Yet the employer assigned only
a 50 percent score for that Pointing out that the appraisal
scores accounted for as much as 40 percent of the total marks In
the competition, the unlon submitted that penalizing an employee
19
who lS performing satisfactorily by deducting 50 percent of the
full mark was unreasonable Counsel reviewed a number of cases
where the process resulted In a failing score for the employee-s
appraisals, l e less than 50 percent, even though the appraisals
gave a rating indicating that the employee met requirements In
other words, the superVlsor doing the appraisal had concluded
that the employee was performing satisfactorily, but under the
scorlng system used, that employee gets a failing grade
The unlon took serlOUS issue with the weight of 60 percent
assigned to the interview In the union-s Vlew, that over-
emphasized the value of a - hour interview, In evaluating an
employee-s qualifications and ability This was more so when
much more reliable information was ignored According to the
unlon, information on file about the applicant-s actual job
performance should have received greater emphasis than interview
scores, specially because the posted positions were substantially
similar to the ones held by the applicants
It was specifically pointed out that no resumes were
reviewed and superVlsors were not consulted As a result there
was no consideration glven to the applicant-s past experlence
20
The unlon also took the position that the scorlng of the
interviews by the 3 panel members was inconsistent and
subjective Many examples were given of situations where one or
more members credited an applicant for providing a suggested
answer, while others did not Counsel pointed to other alleged
defects One of the panel members testified that · hour was not
enough to interview an applicant Different questions were
assigned different marks, but the applicants were not made aware
of that Counsel also characterized as .problematic., the
evidence that the total marks for the applicants interviewed on
the first day had been erased and changed by one of the panel
members, after the marks given by the 3 members had been tallied
and averaged The panel member who did the change could not
recall exactly when and why that was done
Denial of interviews to two qrlevors
As noted, grlevors Patterson and Velentzas were screened
out and were denied interviews The onus lS on the employer to
demonstrate that the screenlng was done In a fair and reasonable
manner See Re Quan, 1797/91 (Gorsky) Ms Heidi MacNeil, a HR
Assistant In the Central Region Office, testified about the
screenlng process for discipline Ms MacNeil sent to each
21
District Manager In the reglon, a list of employees from their
district who had applied pursuant to the posting On June 23,
1997, she wrote to the District Managers requesting them to
-review your list and notify me if any of your employees have
discipline that should disqualify them from getting an
interview - The evidence lS that Ms MacNeil was acting on the
instructions of Ms Yolanda Simone, Manager of Human Resources
for Central Region Ms Simone testified that the personnel
files In the Human Resources Dept were incomplete with regard
to employee discipline, and that this necessitated the contacting
of District Managers to get that information
Under cross-examination Ms Simone agreed that there was no
document or criteria outlining how applicants were to be screened
for discipline The district managers were glven no
instructions as to under what circumstances discipline will
disqualify an applicant However, she stated that -everyone
knows what to do with discipline, i t-s the same as it has always
been- When asked what that process was that everyone knew, she
replied -You can-t look at discipline beyond 3 years If there
lS discipline within the last 3 years, the manager has to decide
if that discipline lS relevant, how old it lS and how severe it
lS That is basically a call for the District Manager to make -
22
She emphasized that the District Manager only makes a
recommendation, which may be accepted or rejected by the Regional
Director who had the final decision on whether to screen out an
applicant because of discipline
The employer prepared an Eligibility Review List, which
inter alia, sets out the results of the screenlng for discipline
Of those applicants who otherwise had the seniority to recelve
an interview, 10 had discipline within the previous 3 years The
outcome was as follows
Employee Discipline Supervisor Reqional
on recommendati Director-s
file -on decision
Linda Mike Recommendati
Wisniewski - Written Stephens -on accepted
reprimand requests
July 27/95 discipline
re be waived as
altercation employee has
with D shown
Hildebrande improvement
Ted Felora - 1 day report for - Written
suspenSlon scheduled reprimand
November shift August 31/94
22/95 re re leaving
failure to store prlor
23
to end of Mike Recommendati
shift and Stephens -on accepted
lmproper requests
cashiering discipline
procedures be waived as
employee has
shown
improvement
Dave Written Ursula does Recommendati-
Patterson reprimand re not on accepted
incident of recommend
July 3/96 -
employee
mistook
customer as
a former
shoplifter
and banned
from store
Colin Enrico Written Not Recommendatio
reprimand recommended n not
dated by G B accepted
October interview
13/95 re granted
failure to
report
George 1 day Ursula does Recommendatio
Velentzas suspenSlon not n accepted
May 19/95 re recommend
altercation
with another
employee
Bill Termination to October Mike does not
Tilley re theft 20/96) Vla recommend
reduced to M 0 S
suspenslon
(August 12
24
Recommendati
-on accepted
Robert suspended 5 Outstanding Recommendati-
Saliba working days M 0 S on accepted
November 11- allowing
16/96 re application
physical for
altercation promotion
on November
9/96
Susanne Written Gerry would Interview
Scarcello reprimand not granted
December recommend Recommendati-
21/94 re on not
mlsslng accepted
envelope
Written Paul does Recommendati-
Joe reprimand not on accepted
Perciasepe February recommend
15/96 re
inappropriat
e behaviour
toward asst
manager and
other staff
and 3
counsel
letters In
1996
Kenneth Written Doug Recommendati-
French reprimand recommends on accepted
dated Ken be
September included
22/95 re - employee
failure to lS on EAP
report and lS
showing
progress
25
Debra Written Doug Recommendati-
Companaro reprimand recommends on accepted
dated Debra be
December included In
12/94 due to competition
failure to
report
Ms Harfman testified about her own decision, as District
Manager, to recommend that grlevors Patterson and Velentzas be
not interviewed In chief, Ms Hoffman was asked why she made
that recommendation for grlevor Patterson She replied -He had
a poor rating In two columns In the appraisal and I di dn-t
recommend that he be allowed to compete There was also a
reprimand on file I had also met with him and his manager
previously about his overall performance In cashiering- She
reviewed Mr Patter son-s performance appraisal dated September
30/96 She testified that it had a -4 " for communication,
relationship and knowledge of operations and a -5 " for
punctuality and attendance, and that it caused her concern
because that was below the standards expected When asked what
Mr Pat t e r son -s reprimand was about, Ms Hoffman stated, -He had
approached a customer and accused him of being a former
shoplifter It was a case of mistaken identity and the customer
complained and threatened legal action - When asked how that
discipline In 1996 factored In her decision to not allow Mr
26
Patterson to compete In 1997, she said -We have a performance
customer We have . .
lssue, a serVlce lssue lnaccuraCles In
cashiering, and improvement was needed Should he be rewarded
with a full time position?-
Ms Hoffman was also asked In chief why she recommended
that grievor Velentzas be not interviewed She replied that Mr
Velentzas had a one day suspenSlon which she considered to be
-serious discipline-, because it involved a violent interaction
with another employee on the sales floor She said that she was
aware that this discipline was over 2 years old, but stated that
-discipline lasts for 3 years before its forgiven -
Under cross-examination Ms Hoffman agreed that he only
looked at Mr Patter sones 1996 appraisal She did not consider
his next previous appraisal which was In 1994, or the one done
In 1993 She acknowledged that In the 1994 appraisal Mr
Patterson received a 1 for punctuality and attendance which
indicated exceptional performance When counsel pointed out that
Mr Velentzas- discipline was over two years old at the time, Ms
Hoffman agreed, but added -That still is within the 3 year period
and the discipline would count - When counsel as ked -So because
27
it was less than 3 years old you disqualified him., she answered
.yes.
Ms Hoffman testified under cross-examination that she
reviewed only Mr Velentzas. 1997 appraisal When counsel
pointed out that In that, Mr Velentzas received an overall
rating of 2 indicating a better than satisfactory performance,
she agreed but explained .His performance was not the lssue He
did his work well The lssue was that he had a violent
interaction with an employee The discipline was not because of
poor work performance.
The arbitral jurisprudence recognlzes that In certain
circumstances past discipline may be relevant In assesslng an
employee-s qualifications and ability to perform a job for which
he has applied Brown & Beatty, Canadian Labour Arbitration,
(3d Ed ) at 6 3310 summarlzes the principles established In the
case law as follows
There lS a consensus of oplnlon that where it
lS relevant to do so an employer may take into
account the grievor.s past disciplinary record,
including verbal warnings, In assessing his skill
and ability to perform a job for which he has
applied For example, where an employee made an
application for a job which required its occupant
to be reliable and honest, and his prlor
disciplinary record raised a reasonable doubt as
to his reliability, integri ty, or responsibility,
28
it has been held that the employer could properly
consider and weigh such defects In character In
reaching its decision to deny the grlevor the
job By contrast, it has been regarded as
lmproper and unreasonable for an employer to rely
upon a disciplinary offence to deny an employee
a particular job where the nature of that offence
did not reflect on the employee-s ability to
perform the particular job, or where a
substantial period of time had elapsed Slnce the
incident, during which the grlevor had
demonstrated his reformation and rehabilitation
Mr Zachar testified that each incident of discipline was
to be -treated on its own merits-, but did not explain what that
meant According to the case law, discipline may only be
considered where it lS relevant to the assessment of the
employee-s ability to perform the duties of the posted position
The discipline In question must reasonably ralse some concern
or doubt whether the employee has the ability to perform the
duties and responsibilities of the posted position The mere
existence of any discipline, per se, would not be adequate to
disqualify an employee
Thus In Re Miller, 348/82 (Samuels) at p 4, the Board
stated
We do not agree with counsel for the grlevor
when he suggests that the disciplinary record can
never be considered for purposes of promotion
In our Vlew, it all depends on the language of
the collective agreement concernlng promotion
In our case, the agreement requlres that the
29
applicant be -qualified to perform the job- If
there are elements of the disciplinary record
which bear on the applicant-s qualifications to do
the job, then these elements can be considered
The disciplinary record per se lS not relevant,
but there may be matters In this record which do
assist the employer to judge the appl ican t-s
qualifications to do the job This lS the point
made In the case cited to us at the hearing by
counsel for the Liquor Control Board - The
Corporation of the Borouqh of Etobicoke and The
Borouqh of Etobicoke Civic Employees- Union, Local
185 (unreported dated October 23, 1981 )
-
Moreover, even In the face of discipline which lS
otherwise relevant, the employer must consider whether that
discipline has had a corrective effect on the employee, or
whether the employee lS likely to demonstrate the same behaviour
In the future For example, where an employee had been
disciplined two years earlier for failure to report to work on
time, but has had no punctuality problems Slnce then, it lS
indicative of the fact that the discipline has had the desired
corrective effect and that the employee lS now rehabilitated
In those circumstances, it lS inappropriate to disqualify that
employee on the basis of his past incident of discipline, even
though punctuality lS clearly relevant to the lssue of
performance in any job On the other hand, where an employee has
demonstrated a pattern of inappropriate conduct despite
discipline imposed, it would be reasonable to conclude that such
conduct may continue In the future and adversely affect
30
performance In the posted position When revlewlng past
discipline as part of a competition process, the purpose ought
not to be to reward for past good behaviour and penalize for past
misconduct, as Ms Hoffman appeared to do The only relevance
of discipline in this situation is whether or not that discipline
reasonably ralses a concern about the indi vidual S.S
qualifications and ability to do the posted job at the time of
the competition
I have concluded for a number of reasons, that the
employer acted improperly in disqualifying grievors Patterson and
Velentzas There lS no evidence whatsoever before me to suggest
that Ms Hoffman or the Regional Director, put their minds to the
lssue of the relevance of the discipline to future performance
In the posted position, or to the lssue of whether the two
grlevors had been rehabilitated Slnce the discipline Ms
Hoffman disqualified Mr Patterson on the basis of an alleged
written reprimand In 1996 for an incident where the grievor had
mistaken a customer for a former shop-lifter Prior to her
testifying, Mr Patterson had denied that he received any
discipline for that incident He testified that his manager
discussed the incident with him, but no discipline resulted In
the face of this denial, it was incumbent on the employer to
31
produce evidence to establish that the discipline it had relied
on to disqualify Mr Patterson In fact existed This was not
done Ms Hoffman did not testify as to the source of her
information that the grievor had received a letter of reprimand
for that incident No such letter was produced Mr Patterson
testified that the only discipline he had received was a written
warnlng In 1997 for directly accepting hours from another store
There lS no evidence that Ms Hoffman was even aware of this
incident of discipline
In any event, it was very clear form Ms Hoffman.s
testimony that she did not put her mind to the lssue of whether
Mr Patterson or Mr Velentzas had been rehabilitated or whether
they were likely In the future to exhibit the conduct that
resulted In the discipline Her Vlew was that as long as an
applicant had an incident of discipline within the 3 year period
recognized by the sunset clause, he was disqualified This was
clear from her testimony with regard to Mr Velentzas She
agreed under cross-examination that he had otherwise been a good
employee, that his altercation was an isolated incident, and that
Slnce that incident Mr Velentzas had been discipline free for
over 2 years However, she disqualified him because the
discipline was still less than 3 years old She stated that the
problem with Mr Velentzas had nothing to do with performance
32
The problem was that he had discipline within the 3 year period
That clearly indicates that she did not consider the lssue of
rehabilitation and the relevance of the discipline to future
performance as an lssue As indicated by Re Miller, ( supra) the
employer was not entitled to disqualify an applicant because of
discipline, unless that discipline reflected adversely on work
performance
Ms Ho f fman-s approach lS even more objectionable because
the chart set out above at pp 21-23 indicates that some District
Managers did consider rehabilitation as a factor and allowed a
number of employees to compete despite the existence of
discipline within the 3 year period For example, applicant
Linda Wisniewski had a written reprimand In July 1995 for an
altercation with another employee District Manager Mike
Stephens recommended that the discipline be waived because -the
employee has shown improvement- Mr Felora had a one day
suspenSlon as well as a written reprimand within the 3 year
period Yet Mr Stephens recommended that he too be glven an
interview because had had -shown improvement- , Mr Saliba had a
5 day suspenSlon for a physical altercation as recently as
November 1996 His District Manager recommended that Mr Saliba
be allowed to proceed In the competition because he had -an
33
outstanding M 0 S . In each of these examples, the District
Managers. recommendations were accepted by the Regional Director
There lS no evidence as to what considerations went In to the
Regional Director-s decision to accept the recommendations
because he did not testify
This evidence indicates that despite the employer-s goal
of having a consistent recruitment process, at least as far as
revlewlng of past discipline was concerned there was no
consistency In this case
Ms Hoffman also considered a non-disciplinary discussion
she had with Mr Patterson about cashiering procedures as a
factor in her recommendation that he be disqualified According
to documentary evidence, as well as Mr Zachar-s testimony, it lS
clear that such non-disciplinary discussions did not form a
criterion In the screenlng process There lS no evidence that
other applicants were subjected to such scrutiny That lS yet
another example of inconsistency
The evidence does not justify a conclusion that the
discipline of either Mr Patterson or Mr Velentzas brings into
question their ability to perform the duties and responsibilities
34
of a full-time CSR With regard to Mr Patterson, the employer
has not adduced any evidence to establish that the incident of
discipline it relied on even existed The only discipline Mr
Patterson had related to not following proper procedure for
obtaining hours from another store Considering that there lS
no evidence in Mr Pat terson.s appraisals or anywhere else, that
he habitually flouted procedures, it lS not reasonable to
conclude that Mr Patterson will not follow procedures In the
future In any event, this discipline was not relied upon by the
employer Mr Velentzas had engaged In misconduct more than 2
years ago and had been punished The fact that he had not
received any discipline whatsoever for over 2 years Slnce then,
can only be seen as indicative that the discipline has had the
desired corrective effect on Mr Velentzas Certainly the
evidence does not justify a conclusion that Mr Velentzas lS
likely to repeat his misconduct
Additionally, it lS clear from the evidence that Ms
Hoffman applied a much harsher standard on these 2 applicants
than the standards applied on other applicants by other District
Managers Employees who had more serlOUS incidents of discipline
than Mr Patterson and Mr Velentzas received interviews because
they had improved These grlevors did not recelve that some
35
consideration from Ms Hoffman The employer lS not entitled to
apply standards inconsistently If the screenlng could not be
done centrally because the necessary information was not
available on file, the employer ought to have at least provided
some clear guidelines to the various District Managers on how the
screenlng was to be done The failure to do that resulted In
some applicants being judged by lenient standards, while others
were subjected to harsher treatment That lS not acceptable In
a competition process
For the foregoing reasons I find that the employer failed
to properly assess the qualifications and ability of Mr
Patterson and Mr Velentzas when they were denied interviews
The appropriate remedy lS set out later In this decision
Alleqed fundamental flaws In the competition
In numerous decisions, this Board has reviewed the
obligations of an employer In assesslng the qualifications and
ability of job applicants In the face of a relative equality
clause Employer counsel questioned the relevance of prior GSB
decisions rendered under the OPSEU collective agreement, claiming
tha t -the language was different- However, she did not point to
any difference In substance and meanlng, flowing from any
36
difference In language I find that the present collective
agreement, like the OPSEU agreement, contains a relative equality
provlslon The observations made by the Board in the OPSEU cases
were not peculiarly dependent on particular words In the OPSEU
provlslon They are equally applicable to the relative equality
clause In article 31 4 (b) of the LCBO agreement
In Re Marek, 414/83 the Board observed as follows at p 5
.It lS hard for this Board to understand how this
could occur, In Vlew of the repeated direction
this Board has glven on the need to consult
personnel files and candidates. superVlsors,
particularly when one of the candidates only lS
known to the interviewers. see, for example,
MacLellan and DeGrandis, 506/81, 507/81, 690/81
and 691/81, wherein the jurisprudence lS
summarized at page 25 and 26
The jurisprudence of this board has
established varlOUS criteria by which to
judge a selection process
1 Candidates must be evaluated on all the
relevant qualifications for the job as set
out In the Position Specification
2 The varlOUS methods used to assess the
candidates should address these relevant
qualifications insofar as it lS possible
For example, interview questions and
evaluation forms should cover all the
qualifications
3 Irrelevant factors should not be
considered
37
4 All the members of a selection committee
should reVlew the personnel files of all
the applicants
5 The applicants. supervisors should be asked
for their evaluations of the applicants
6 Information should be accumulated In a
systematic way concernlng all the
applicants
See Remark, 149/77, Quinn, 9/78, Hoffman, 22/79,
Ellsworth et aI, 361/80, and Cross, 339/81
In Leslie, 126/79, the prlmary basis on which
this Board ordered a new selection process was
the fact that the interviewers knew one of the
candidates, and had relied on the interviews
alone, without any recourse to the supervlsors of
other candidates Nor In, Leslie, had the
interviewers referred to the gr ievor.s personnel
file or performance appraisals In our Vlew,
this conduct alone fatally flaws the selection
process undertaken by the interview panel here .
While the Board has repeatedly set out the foregoing as
a guideline for the proper conduct of a competition process, it
has not regarded the failure by the employer to comply with those
criteria by itself, as reason to quash the results of the
competition Thus, In Re Saras, 457/85 (Swan), one of the
complaints of the unlon was that the selection panel had failed
to reVlew the complete personnel files of the candidates The
Board found that all candidates were permitted to fill out an
application form which provided space on two pages to describe
an appl ican t.s qualifications and employment history, and were
38
invited to submit any additional information on a separate sheet
The grievor-s personnel file included information about some
temporary jobs the grievor had done which would have been of some
relevance The commi t tee-s failure to reVlew personnel files
deprived it of this information Yet the Board took into account
the fact that the grlevor had the opportunity and had been
invited to set out his employment history In the detailed
application form He had not mentioned the temporary jobs, which
he claimed would have assisted his candidacy The Board
commented that the grievor must have not thought that the jobs
In question were sufficiently important to set out In the
application form Noting that -i t lS possible to pick holes In
almost any process run by mortal human beings-, the Board
dismissed the grlevance, concluding as follows at p 13
In the result, while we may not be happy with
everything that happened In the course of the
selection, we have come to the conclusion that
the process as a whole was not unfair nor was it
calculated to lead to an incorrect result We
have also concluded that, on a somewhat larger
body of evidence placed before us at the hearing,
and on an objective basis, Ms Parisien was In
fact better qualified for the specific job at
lssue than was the grlevor
In Re Falcioni, 2308/91 (Kaplan) , the Board found that
-The mistakes in this case are serlOUS and disturbing, but we are
satisfied on the evidence before us that the selection committee
39
and the employer obtained the information it needed to choose
among the applicants and that the correct choice was ultimately
arrived at . The grlevance was dismissed because . none of
the mistakes lS of such fundamental nature as to have
irreversibly tainted the result.
In Re Laforest, 1983/87 (Roberts) the Board at p 12
reviewed the list of McLennan and DeGrandis criteria, and
observed
This Board has consistently held that failure
to consult personnel files and reports of
supervlsors are significant flaws In the
selection procedure Where the Board finds such
flaws to exist it generally invalidates the
competition In question
Yet the Board has been prepared to overlook flaws in the
face of evidence that it did not prejudice the candidacy of the
grlevor Thus In Re Renton (Roberts) , the selection committee
had failed to consult personnel files and reports of supervlsors
However, the evidence was that two of the three panel members
had directly supervised the grlevors for a number of years, and
that they had briefed the third member completely and objectively
as to the qualifications and abilities reflected in the gr ievors.
personnel files In the circumstances, the Board did not disturb
the results of the competition In contrast In Re Laforest,
40
( supra) the Board found that the one member who briefed the other
3 panel members had only supervised the grlevor for a few months
and that at a relatively low intensity level There the Board
concluded that the failure to reVlew personnel files and
superVlsors reports raised great potential for prejudice
In Re Wayne & Lowe ( supra) the Board was critical of the
conduct of a panel which scored an interview process In the
following circumstances
Once a consensus on scores was reached a list
of all competitors was drawn up with their scores
In all areas set out and totalled It appears
that after this list was drawn up further changes
were made to various individuals. scores Neither
of the two committee members who gave evidence at
the hearing was quite sure when the changes were
made
In Re Wriqht/Wasky, 1832-33/91 (Watters) at pp 41-42 the
Board wrote
The Board has consistently determined that
this task cannot be properly or adequately
performed on the basis of just an oral interview
It has required that a broader base of
information be assessed for purposes of complying
with the contractual direction contained within
article 4 3 This has included resort to
personnel files, particularly the performance
appraisals contained therein, and supervlsory
comments An example of where this approach was
employed lS the award In Palatino, Raqos,
Patterson The majority of the Board there
stated as follows
41
. We also find, however, that the
employer In this case relied too heavily
on the interview results The authorities
are extremely clear that the employer must
not rely solely on interviews In job
posting cases At the very least the
employer must also conduct reference
checks of all candidates with immediate
superVlsors and reVlew all applicants.
personnel files , if the employer
relies solely on the interview for making
an assessment of candidates it does so at
its peril .
(Page 45 )
It lS clear to this Board that the panel In
this instance relied excessively on the scores
generated through the interview process In the
case of Mr Wasky, they did not conduct a
reference check nor reVlew his performance
appraisals, as contained in the personnel files
Ms Inkster agreed that In assessing his related
experlence, she relied exclusively on the
information he presented at the interview
Similarly, Mr Van Sickle appeared to make a
conSClOUS decision to disregard knowledge that he
had pertaining to Mr Was ky.s past experlence
Both panellists were of the Vlew that it was
incumbent on all applicants to demonstrate their
experlence, skills and qualifications through
their answers to the questions posed at the
interview We have no doubt glven the pan e I .S
failure to reVlew other sources of relevant
information, that Mr Wasky was effectively
excluded from further consideration solely
because of the interview scorlng
In Re Poole (1988) 2508/87, the vacancy had been awarded
solely on the basis of interview scores The Board noted at p 4
There must be a full gathering of information
concernlng the qualifications and ability of the
applicants It lS simply not satisfactory to
42
conscientiously l.gnore information as was done
here For some reason, the grlevor did not do
well at the interview (we have a great deal of
difficulty understanding this and we will have
something to say about this In a moment) The
three members of the panel were left with the
. . that the successful candidate had
lmpreSSlon
better qualifications and experlence than the
grlevor, but a look at their application forms
would have confirmed that the grlevor was a
senlor nurse with much experlence In the very
matter which was to be taught to the 800 staff
members at the hospital, while the successful
candidate had just graduated from nursing school,
and had no experience whatso -ever In this area
In our Vlew, the decision of the panel was
simply perverse and this resulted from its
profoundly flawed procedure
At p 7 the Board concluded
In summary, we find that the selection process
was entirely inadequate The ultimate total
reliance on the interview as an information-
gathering and scorlng tool resulted In an
assessment of the relative merits of the
candidates which had no real basis In fact In
particular, the panel failed utterly to see the
grlevor as she was, in spite of the fact that the
information was In its hands or readily
available
DECISION
The process followed In this competition was very
different from many aspects from the typical competition The
three person panel lS not properly described as a -selection-
panel All of its members were emphatic during their testimony
that their sole responsibility was to interview and score the
43
candidates In accordance with -the process- Once the score
sheet was handed in, they had no further involvement in any other
aspect of the competition process Indeed, there was no person
or persons who admitted to responsibility for actually selecting
the successful candidates One of the panel members best
described the situation, when he was asked whether he was
involved In the selection of who gets the jobs He replied -No
one selected them The process itself decided it- The scorlng
of the 2 appraisals was performed by human resources staff almost
as a clerical function, by applying a matrix to obtain scores to
the two performance appraisals The fact that the process was
unusual lS not by itself objectionable The lssue lS whether it
resulted In proper consideration being glven to all of the
relevant information available In assesslng qualifications and
ability as contemplated by article 31 4 (b) After a careful
review of the evidence I have concluded that as a result of the
cumulative effect of many deficiencies, the whole process was
fundamentally flawed so that its results cannot be accepted
The Board has repeatedly held that reliance solely on
interview results lS not acceptable as a means of assesslng
qualifications and ability The employer here did not do that,
but clearly over-valued the interview scores to the exclusion of
44
other relevant and more reliable information The employer gave
consideration to attendance and discipline, but only for purposes
of the initial screenlng Once applicants got beyond that
hurdle, apart from the interview scores, the only other
information considered was that contained in two appraisals No
resumes were reviewed Complete personnel files were not
considered Supervisors were not contacted Particularly
considering that all of the applicants had performed for
considerable periods In part-time CSR positions which had
substantially similar duties, the reliance on a one half hour
interview to the exclusion of other information, is unacceptable
The grlevors testified about the extra duties they had
performed In their part-time CSR positions, including In some
cases the runnlng of shifts This not only demonstrates
experlence, but also the level of confidence the superVlsors
exhibited in their ability and reliability They had performance
appraisals which were satisfactory or better overall When such
senlor employees performed poorly on a one half hour interview,
it was not reasonable for the employer to simply accept the
scores as representative of the qualifications and ability of the
employees without consulting with the supervlsors The
supervlsors have had first hand knowledge about the level of
45
performance of the employees Their information lS at least as
reliable, if not more reliable, than interview score Mr Zachar
took the position that resumes were not reviewed out of a concern
that it would glve an unfair advantage to individuals who were
more skilled In writing a good resume One cannot help but
wonder why the employer did not have a similar concern that
individuals who were good performers at interviews In an
atmosphere of pressure would have an unfair advantage, over
others who were competent workers but not good performers at
interviews
If the employer did not wish to reVlew resumes, it had
the obligation to obtain the information that would have been
contained In a resume In some other manner Unlike in Re Saras
(supra) , here the employer did not glve the applicants an
opportunity to set out their experlence, employment history or
any other relevant information such as letters of commendation,
in the application form The applicants were required to use the
Q-35 form and it had space only for the most routine information
The argument that experlence was indirectly considered because
the applicants with more experience will be better able to answer
the interview questions is without merit Experience lS a matter
of fact, quite apart from an employees ability use that
46
experlence to answer a question under the stressful conditions
of an interview On the basis of the evidence I find that
experlence received no consideration at all In the process
There lS no suggestion of anything sinister However,
some of the evidence about the tabulation of scores lS
troublesome There were discrepancies in the scores entered for
the same applicant in different documents No one could explain
why the same applicant had one mark in the initial recording and
a different score in the final document Without gOlng into any
detail, I note that on the interview sheets for many applicants
filled in by some panel members, a total mark had initially been
entered in pencil, then erased and a different mark written over
The erased marks corresponded to the marks entered In another
document which was not used for the awarding of positions This
clearly suggests that the interview sheets filled In and scored
by the 3 panel members were at some point totalled and an average
obtained by dividing by 3 The resulting score had then been
entered on a score sheet recording scores for all applicants
Then someone had gone back and altered the scores on the
individual score sheets and the procedure was repeated, resulting
in a different average score It was this latter score which was
used ultimately In the awarding of positions
47
No one testified to explain why and how this process of
changing marks was carried out Ms Shelly McIntyre, one of the
panellists, admitted that she would have been the one who did the
erasure and the changes, but she had absolutely no recall of the
circumstances which led her to do so The interview was an
extremely critical, if not determinative part, of the competition
process It lS imperative that the employer explain the process
it followed to arrlve at interview scores No assumptions can
be made that there was some sinister activity going on, from the
mere fact that Ms McIntyre could not recall when, why or how she
changed the marks After all, she was testifying several years
after the event However, In a matter so critical to employee
rights under the collective agreement, it lS to be reasonably
expected that the employer would keep a record of the process it
followed step by step, particularly where unusual steps are taken
such as eraslng and substituting marks By not doing so, it
invites SUsplClon, and challenges to the reliability of the marks
used The employer should know that it would be obliged to
explain the process followed, In the event a grlevance lS filed
It lS imprudent, to say the least, for an employer to put itself
in a position where at arbitration it cannot explain how and why
marks happened to be changed
48
The Board has considerable concern not only about the
failure by the employer to consider information other than the
2 most recent appraisals, but also about the manner in which it
considered those 2 appraisals As the Board did in Re Netta et
al (supra) I find that the straight mathematical converSlon of
appraisals, while simpler and easier to apply, failed to reflect
the true content and opinion expressed therein by the appralslng
supervlsor The problem was compounded by the decision of the
employer to focus solely on the ratings for individual areas of
competency, and 19nore the overall rating as well as positive
assessments In the comments section
Through its failure to comply with its own policy of
carrYlng out annual performance appraisals, the employer found
itself In a position where it was not In a position to evaluate
the appraisals for the same period for all of the applicants
However, it was In a position to compensate for that
disadvantage, by canvasslng superVlsors to satisfy itself that
the available appraisals were representative of the employeees
qualifications and ability, and not an aberration from the usual
standards The way the employer did it, the review of appraisals
became a matter of luck of the draw For example, the 1995
49
appraisal that was reviewed for Mr Patterson contained a less
than satisfactory rating for attendance and punctuality This
was held against him In screenlng him out of the competition
If a 1995 appraisal had not been done for him (some employees
had no appraisals done Slnce 1992 or 1993 ) the employer would
have used his next previous appraisal, l e the 1994 appraisal
In contrast to the 1995 appraisal, the 1994 appraisal had an
excellent rating for attendance and punctuality He lost out
because he happened to have a 1995 appraisal done
Mr Pat t e r son .S case also illustrates another problem
with the employer-s process Had the employer reviewed the
complete personnel file, it would have discovered that Mr
Pat t e r son .S attendance and punctuality dramatically changed
between 1994 to 1995 Remembering that the only relevant lssue
lS the likelihood of Mr Patterson attending work regularly and
punctually In 1997 and thereafter, the question must necessary
arlse whether or not his problems In 1995 were caused by some
particular reason such as an illness or some other personal
problem, and if so, whether such impediment still existed To
answer this question the employer could have consulted Mr
Pa t terson.s pas t superVlsors, or Mr Patterson himself could have
been asked for an explanation Neither was done Instead,
50
because the appraisal that happened to be reviewed had a negative
rating, he screened out without further . .
was any lnqulry
A further flaw lS apparent In the manner the employer
assessed the relative equality of the applicants The Board has
no concerns about the 20 percent spread used for relative
equality However, the problem lS that the employer compared
applicants to the top score of 95 for each of the 37 vacanCles
When the top scorer lS awarded a position, he lS no longer
competing for the . . . The comparison then must
remalnlng vacanCles
be between the highest scorer among those not yet awarded a
position, and applicants who were senlor to him Indeed Mr
Zachar testified that this was exactly what was contemplated by
the employer-s own policy It lS beyond doubt that In this
particular competition the employer erred and failed to follow
its own policy, resulting In an inappropriate consideration of
relative equality
The Board does not doubt that the employer was making an
honest and legitimate effort to come up with a consistent and
administratively simple recruitment process Subject to any
estoppel arguments the union may elect to make In future cases,
the employer was entitled to devise a new process, but only on
condition that it met its obligations under the collective
51
agreement In view of the many defects the Board has found, and
the cumulative effect of those defects, the Board cannot agree
with employer counsel that despite these defects the results of
the competition should be allowed to stand In all of the
circumstances, the process followed by the employer as part of
its obligation under article 31 4 (b) to evaluate the relative
qualifications and ability of the applicants was inadequate, In
that it failed to elicit In a systematic fashion sufficient
information to permit a fair and reliable judgement about the
applicants Therefore the results of this flawed process cannot
be allowed to stand
The Board concludes as follows
(A) The board allows the grlevances of Mr Patterson and
Mr Velentzas In that it finds that the employer did not assess
their qualifications and ability In compliance with article
31 4 (b) when they were denied interviews The Board finds that
they were qualified and were entitled to participate fully
(B) The Board allows the grlevances of Mr Everest, Mr
Felora, Mr MacKay and Mr Sam to the extent that the competition
which resulted In their not being awarded positions was so
fundamentally flawed, that its results are not reliable
52
Remedy
The union accepted that if the grlevances are allowed on
the basis of fundamental flaws In the competition process, the
appropriate remedy is to order a re-run of the competition The
employer also did not disagree with that However, the parties
were in disagreement as to who should be allowed to participate
In the competition to be re-run The unlon took the position
that the new competition should be restricted to the grlevors and
the 37 successful candidates (incumbents) who were made parties
to this proceeding The employer on the other hand submits that
all of the applicants who were found to be qualified to be
interviewed, including those who did not grleve, should be
allowed to participate In the re-run competition Employer
counsel pointed out that in Re Netta (supra) the Board did not
restrict the competition ordered to be re-run to the grlevors and
incumbents
The Re Netta decision does not include any discussion
about who should be allowed to participate In the re-run
competition The Board merely orders that -The appropriate
remedy in the circumstances lS to requlre the LeBO to re-run the
competi tion- Thus it appears that the lssue of the extent of
53
participation was not raised In that case Among the many GSB
decisions submitted to me, I have found some decisions which
restrict the re-run competition to the grievor(s) and the
incumbent(s), and others which place no such limitation
However, none of those decisions contain any reasonlng for the
order, suggesting that the issue was not argued before the Board
In the present case the lssue has been squarely put before me
and I must deal with it
All of the applicants participated in the competition In
question Of those unsuccessful, only some grieved that their
rights had been infringed The others, the non-grlevors, have
not asserted that their rights have been In any way infringed
Nor has the union made such a claim on their behalf, by filing
a unlon grlevance In those circumstances the Board lS of the
Vlew that the remedy rendered In order to address these 6
individual grlevances should not extend any rights or benefits
to those who did not grleve
In Re Zuibrycki, 100/76 (Pritchard) , affirmed R v
0 P S E et aI, (1982 ) 35 o R ( 2n:1) 670 (Ont Div ct ) , the
Board remedied a flawed competition by ordering the appointment
of the grlevor to the vacancy In that case the employer had
54
argued that the Board should not award the position to the
grievor because there were other applicants who had not grieved,
but were also relatively equal and had more seniority than the
grlevor The Board rejected that reasonlng While the factual
basis In that case was different In that the Board there was
considering the appointment of the grlevor, and not ordering of
a re-run, its observations are instructive, and In my Vlew
equally applicable to the circumstances here Thus it stated
Turning to the particular facts of the case
before us, it must be remembered that the earlier
panel of the Board found that the grlevor
possessed ability and skills at least equal to
all of the candidates In each competition In
the result, he should have prevailed over [the
successful applicants], each of whom had less
seniority than the grlevor
There were other candidates more senlor than
the grlevor who, on the Board.s findings, were
relatively equal In ability and skills and who
therefore would have been entitled to prevail
over the grlevor if they had grieved and if the
same findings of fact had been made However,
they did not grleve and have not grieved to this
date They therefore have forfeited any claim
they may otherwise have had to the positions It
lS widely accepted in labour relations that those
with a grlevance should ralse the matter In a
timely fashion so as to allow the parties to the
collective agreement to assess the situation and
respond appropriately In particular, if the
other candidates had grieved, the grievor.s case
and the employer-s case may well have been
different However, by not grlevlng the other
candidates are now foreclosed from claiming (or
having claimed for them by the employer) any
rights In this arbitration
55
See also, Re Harris-Bernard 97/94 (Roberts) and Re
Frisken, 2034/94 (Gray)which follow the same approach
In consideration of all of the foregoing the Board orders
as follows
(a) The employer shall re-run the competition restricted
to the SlX grlevors and the incumbents, In accordance with the
requirements of the collective agreement and the findings in this
decision
(b) To the extent it lS possible, the employer shall
disregard the experlence and knowledge acquired by the incumbents
as a result of performing In the posted position following the
first competition
(c) If any of the grlevors are successful In the
competition re-run, the employer shall compensate them for their
losses, calculated on the basis that they were entitled to have
been appointed on the day the appointments were made following
the first competition
The Board retains jurisdiction to resolve any
disagreements the parties may have in the implementation of this
decision
56
Dated this 24th day of February 2000 at Hamilton, Ontario
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Nimal V Dissanayake, Vice-Chair