HomeMy WebLinkAbout1999-0405.Union Grievance.01-05-09 Decision
o NTARW EMPLOYES DE L4 COURONNE
CROWIVEMPLOYEES DE L '()NTARW
GRIEVANCE COMMISSION DE
~ SETTLEMENT REGLEMENT
0nbIrI0 BOARD DES GRI EFS
180 DUNDAS STREET WEST SUITE 600 TORONTO ON M5G 128 TELEPHONElTELEPHONE. (416) 326-1388
180 RUE DUNDAS OUEST BUREAU600 TORONTO (ON) M5G 128 FACSIMILE/TELECOPIE. (416) 326-1396
GSB#0405/99
UNION#99U026
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Dmon
(Dmon Gnevance)
Gnevor
- and -
The Crown m RIght of Ontano
(Management Board Secretanat)
Employer
BEFORE RandI Hammer Abramsk, Vice-Chair
FOR THE Knstm A. ElIot, Counsel
GRlEVOR ElIot, SmIth
Bamsters and SolIcItors
FOR THE Kelh Burke Counsel
EMPLOYER Legal ServIces Branch
Management Board Secretanat
HEARING Februan 28 2001 conference call March 30 2001
2
AWARD
ThIS IS a polIcy gnevance contestmg the Employer's posItIOn that mdIvIduals who
apply for restncted competItIOns under ArtIcle 20.2 3 are not entItled to gneve wIth
respect to those competItIOns The Umon seeks a declaratIOn that such mdIvIduals do
have recourse to the gnevance procedure m these CIrcumstances and that the standard of
reVIew should be the same as for classIfied employees - to have theIr qualIficatIOns fully
and fairly assessed and to partIcIpate m a competItIOn free of fatal flaws
The relevant sectIOns of ArtIcle 20 Employment StabIlIty are set forth below'
20.2 NOTICE AND PAY IN LIEU
202 1 An employee IdentIfied as surplus shall receIve SIX (6) months notIce of
lay-off or wIth mutual consent, an employee may resIgn and receIve
eqUIvalent pay m lIeu of notIce
20 2.2
20 2 3 Where an employee accepts pay m lIeu of notIce pursuant to thIS artIcle
any further entItlements under thIS Central CollectIve Agreement are
forfeIted save and except any nghts under ArtIcle 53 or 78 (TermmatIOn
Payments) and ArtIcle 203 (SeparatIOn Allowance) or paragraph 4 of
AppendIx 9 (Employment StabIlIty) The employee wIll be elIgIble to
apply for restncted competItIOns from the last day of work untIl twenty-
four (24) months from the date on whIch lay-off would otherwIse have
occurred,
2024
20 2 5 Where an employee who accepts pay m lIeu of notIce IS re-appomted to a
posItIOn m the Ontano PublIc ServIce after the ongmally projected lay-off
date, and pnor to the expIratIOn of a further twenty-four (24) months, the
employee wIll repay to the mImstry all momes, excludmg tUItIOn fees,
receIved under ArtIcle 20 3 (SeparatIOn Allowance) or paragraph 4 of
AppendIx 9 (Employment StabIlIty) The employee's contmuous servIce
3
date for all purposes except ArtIcle 53 or 78 (TermInatIOn Payments) shall
be deemed to Include both servIce up to the last day of actIve work and the
accumulatIOn of servIce after the date of re-appoIntment. The new servIce
date for purpose of termInatIOn pay shall be the date on whIch the
employee recommences work.
Also relevant IS ArtIcle 22, Gnevance Procedure In part, ArtIcle 22 provIdes as follows
22 1 It IS the Intent of thIS Agreement to adjust as qUIckly as possIble any complaInts or
dIfferences between the partIes ansIng from the InterpretatIOn, applIcatIOn,
admInIstratIOn or alleged contraventIOn of thIS Agreement, IncludIng any questIOn
as to whether a matter IS arbItrable
Stage One
22 2 1 It IS the mutual desIre of the partIes that complaInts of employees be adjusted as
qUIckly as possible and It IS understood that If an employee has a complaInt, the
employee shall meet, where practIcal, and dISCUSS It WIth the employee's
Immediate supervIsor
Stage Two
22 3 1 If the complaInt or dIfference IS not resolved under Stage One, the employee may
file a gnevance, In wntIng, through the Umon, wIth the semor human resources
representatIve In the mImstry or hIS or her desIgnee
Arguments of the Parties
A. The Employer
The Employer contends that under ArtIcle 20.2, an employee "may resIgn and
receIve eqUIvalent pay In lIeu of notIce" In ItS vIew resIgnatIOn precedes the receIpt of
pay In lIeu and once the employee resIgns, he or she IS no longer an "employee" of the
Ontano publIc servIce entItled to utIlIze the gnevance arbItratIOn provIsIOns In the
collectIve agreement. The gnevance arbItratIOn process, It submIts, IS specIfically lImIted
to the Umon and "employees" It does not cover former employees, except for events that
take place whIle the IndIVIdual IS employed (i e termInatIOn) It contends that events
4
whIch anse after an employee's resIgnatIOn cannot be challenged through the gnevance
arbItratIOn process
The Employer submIts that all potentIal gnevors under ArtIcle 20 2 3 no longer
have "employee" status They are no longer part of the bargaInIng umt and have no
access to the gnevance arbItratIOn procedure under the collectIve agreement. ThIS Board,
It contends, has no jUnSdIctIOn over such IndIVIduals
In support of ItS posItIOn, the Employer cItes to Re HoneJM'ell Ltd And United
Automobile Workers Local 80 (1975) 10 LAC (2d) 446 (Hinnegan) In that case, a
former employee alleged a vIOlatIOn of the long-term dIsabIlIty benefits provIsIOn In the
collectIve agreement. She was not, at the tIme her claim arose or at the tIme her
gnevance was filed, an employee of the company The board of arbItratIOn determIned
that because she was not an employee covered by the collectIve agreement at the relevant
tIme she had "no status whatsoever to file and pursue the gnevance procedure provIded In
that collectIve agreement."
The Employer contends that the fact that the Board does not have jUnSdIctIOn
over such matters may lead to an IneqUIty IS not determInatIve In support, It cItes to
OPSEU (Patricia Campbell) and Ministry of Health GSB No 1088/86 (1988) (Draper
Vice-Chair) In that case, the Board ruled that It had no jUnSdIctIOn over an allegatIOn by
an unclassIfied employee that the employer vIOlated ArtIcle 4 In the conduct of a job
competItIOn, It noted that ItS rulIng left members of the unclassIfied servIce WIth no
5
recourse when they alleged that a competItIOn was Improperly conducted, but ruled at p
2 that "thIS seemIng IneqUIty IS for the partIes, not the Board, to address" The same, It
argues, IS true In the Instant case
The Employer further argues that under ArtIcle 20 2 3 an employee who elects
pay In lIeu specIfically forfeIts "any further entItlements under thIS Central CollectIve
Agreement" save and except for a lImIted number of specIfically lIsted nghts under
ArtIcle 53 or 78 and ArtIcle 20 3 or paragraph 4 of AppendIx 9 It submIts that those
lIsted nghts anse whIle the IndIVIduals are stIll employed, In contrast, It argues that theIr
elIgIbIlIty to apply for restncted competItIOns anses after they are no longer "employees"
of the government. The Employer asserts that an employee may gneve the specIfic
entItlements set out In ArtIcle 20 2 3 but may not gneve any other matter
The Employer contends that the last sentence of ArtIcle 20 2 3 that "[ t ]he
employee wIll be elIgIble to apply for restncted competItIOns from the last day of work
untIl twenty-four (24) months from the date on whIch lay-off would otherwIse have
occurred" IS a gratUItous benefit offered to employees who had been In the publIc servIce
for some tIme It allows them to apply for restncted competItIOns whIch, as a non-
employee, would otherwIse be closed to them, It argues, however that It makes no sense
from a practIcal pOInt of VIew to allow these non-employees to gneve such competItIOns
Without semonty It submIts that they stand lIttle chance of successfully competIng
agaInst employees wIth semonty because of the relatIve equalIty provIsIOn In ArtIcle
63 1
6
In support of thIS posItIOn, It cItes to OPSEU (Garrison) and Ministry of
Transportation GSB No 1229/94 (1995) (Kaplan, Vice-Chair) In whIch the Board
ruled, among other thIngs, Inter alIa, that where the successful candIdate In a job
competItIOn was a classIfied employee wIth many long years of servIce he would have
lIkely trumped the gnevor an unclassIfied employee, even If the gnevor had receIved a
perfect score It also cItes to OPSEU (Norland) and Ministry of Correctional Services
GSB No 3160/92 (1993) (Gorsky Vice-Chair) In whIch the Board ruled at p 22 that the
rules of contract InterpretatIOn owe a good deal to common sense and must be applIed
wIth a good deal of common sense
The Employer contends that It makes lIttle sense to allow such gnevances, whIch
would deplete the Umon's resources It submIts that allowIng such gnevances would
open the floodgates SInce every restncted competItIOn that non-employees are allowed to
partIcIpate In would be open to challenge
The Employer further contends that under the specIfic terms of ArtIcle 20 2 3
IndIVIduals who elect pay In lIeu "forfeIt" "any further entItlements under thIS Central
Agreement" whIch Includes the gnevance arbItratIOn provIsIOns of ArtIcle 22 It asserts
that by excludIng the gnevance procedure the partIes expressed an Intent that the
gnevance procedure would not apply "save and except" for the lIsted provIsIOns
7
In the alternatIve, the Employer argues that the "nght" surplus sed employees have
to apply for restncted competItIOns should be lIterally Interpreted to mean that they are
"elIgIble to apply for restncted competItIOns " penod, If they are precluded from
applYIng, It submIts that may be gneved, but nothIng further ThIS lImIted "nght" It
asserts, IS what the partIes agreed to In ArtIcle 20.2 3 and the Board has no power to alter
or amend the collectIve agreement. Acceptance of the Umon's posItIOn, It asserts, would
constItute an alteratIOn of the partIes' agreement. The Board, It argues, must gIve the
language ItS "plaIn meamng" CItIng OPSEU (Norland) supra It contends that the fact
that the gnevance procedure IS lImIted to "employees" further underscores that non-
employees should not be allowed to gneve under ArtIcle 20.2 3
The Employer also cItes to OPSEU (AhluJ1,alia et al.) and Ministry of
Transportation and Communications, GSB No 725/83 (l984)(Spnngate, Vice-Chair) In
that case the Board ruled that the fact that unclassIfied employees could apply to
competItIOns dId not gIve them the nght to gneve them,
FInally the Employer submIts that If the Board determInes that such IndIVIduals
may gneve under ArtIcle 20.2 3 the standard should be lImIted to "bad faith" The
Employer argues that non-employees should not have greater nghts In terms of the
arbItral standard of reVIew than unclassIfied employees
8
B. The Union
The Umon submIts that the fundamental questIOn IS whether ArtIcle 20.2 3 creates
a substantIve nght capable of gIVIng nse to a "dIfference between the partIes" If so the
matter IS arbItrable under SectIOn 7(3) of the Crown Employees Collective Bargaining
Act (CECBA) and the partIes cannot contract out of that statutory provIsIOn,
The Umon contends that the fact that the surplus employees are no longer
"employees" IS Irrelevant. The pIvotal Issue, It submIts, IS whether the collectIve
agreement affords the surplussed employees a substantIve nght. It notes that even In Re
HoneJl>>'ell Ltd and United Automobile Workers Union, Local 80 supra, cIted by the
Employer It was noted that the Ontano Court of Appeal, In Re Blouin DrY)1,all
Contractors Ltd And United Brotherhood of Carpenters and Joiners of America, Local
2486 (1975) 8 O,R. (2d) 103 held that where the collectIve agreement In questIOn
expressly confers benefits on non-employee members of the umon those benefits could
be the subject of a gnevance and wIthIn the jUnSdIctIOn of a board of arbItratIOn under the
agreement. The key the Umon submIts, IS whether the agreement confers a nght or
benefit on a non-employee member
The Umon asserts that ArtIcle 20 2 3 clearly confers a nght and benefit on
surplus sed employees - the nght to apply to restncted competItIOns for a penod of
twenty-four months It submIts that the language IS clear on ItS face, and that It IS one of
the Inducements that was bargaIned for along wIth sIx-months pay In lIeu, severance pay
and termInatIOn pay to encourage employees to elect the pay In lIeu optIOn rather than
9
seek to dIsplace another employee or seek redeployment. The rIght to apply to restrIcted
competItIOns, It argues, IS a real benefit and provIdes surplussed employees wIth an
opportumty to return to the publIc servIce Under ArtIcle 2025 If they apply to a
competItIOn and are successful wIthIn the twenty-four month perIod, theIr contInuous
servIce date Includes theIr prIor servIce It contends that thIS IS a sIgmficant substantIve
rIght, not a gratUItous benefit, enforceable through the grIevance arbItratIOn procedure
In support, It cItes to OPSEU (McIntosh) and Ministry of Government Services GSB No
3027/92 (1993)(DIssanayake, Vice-Chair)
The Umon also submIts that the partIes dId not exclude such matters from
grIevance arbItratIOn under ArtIcle 20.2 3 The fact that the grIevance procedure IS not
specIfically exempted from forfeIture does not mean, It submIts, that the grIevance
procedure was excluded, It contends that thIS provIsIOn does not read out the grIevance
procedure It only reqUIres an employee to gIve up "entItlements" under the Central
Agreement. The word "entItlements" It contends, refers to substantIve rIghts, not
procedural rIghts In ItS vIew just as the employee's rIght to grIeve hIS or her
entItlements under ArtIcle 53 or 78 and ArtIcle 203 or paragraph 4 of AppendIx 9
remaIn, so too does the rIght to grIeve the rIght to apply to restrIcted competItIOns In
support the Umon cItes to OPSEU (Brown, Murdock Rogers) and Ministry of Municipal
Affairs & Housing GSB No 1343 (1 997)(Kaplan, Vice-Chair) In whIch Vice-Chair
Kaplan concluded at p 7 In dicta, that "the employer's submIssIOn that once an employee
accepts the ArtIcle 20.2 3 optIOn he or she has no further rIghts to grIeve about anythIng
IS a proposItIOn that seems dubIOus, at best."
10
Instead, the Umon contends that exclusIOn of a nght must be expressed In very
clear terms and that the language of ArtIcle 20.2 3 and ArtIcle 22 falls short, The Umon
contrasts the very clear exemptIOn from arbItratIOn of the dIscharge of probatIOnary
employees found In ArtIcle 21.2 ("[f]or greater certaInty It IS understood that nothIng In
ArtIcle 21 1 confers on a probatIOnary employee any nght to gneve or arbItrate hIS or her
dIsmIssal) wIth the language In ArtIcle 20.2 3 It submIts that If the partIes Intended to
exempt the nghts granted In ArtIcle 2023 from arbItratIOn, they would have done so
USIng sImIlar contractual language
In support of ItS contentIOn, the Umon cItes Re COlp of City of Windsor and
International Assoc of Firefighters Local 455 (1975) 8 L.A>C (2d) 320 (Weathenll)
and Re International Waxes Ltd and Oil, Chemical and Atomic Workers International
Union (1977), 17 LAC (2d) 62 (SchIff) whIch hold that "clear language" would be
reqUIred to bar a matter from arbItratIOn, If It IS possIble at all
Further the Umon contends that even If ArtIcle 20.2 3 could be construed to read
out the gnevance procedure, such a constructIOn would be vOId under SectIOn 7(3) of
CECBA That provIsIOn reads follows
Every collectIve agreement relatIng to Crown employees shall be deemed
to provIde for the final and bIndIng settlement by arbItratIOn by the
Gnevance Settlement Board, wIthout stoppage of work, of all dIfferences
between the partIes an SIng from the InterpretatIon, applIcatIOn,
admInIstratIOn, or alleged vIOlatIOn of the agreement, IncludIng any
questIOn as to whether a matter IS arbItrable
11
In support of Its contentIOn that the partIes cannot contract out the arbItratIOn of
substantIve rIghts under SectIOn 7(3) of CECBA, the Umon cItes to OPSEU (Pietroban)
andMinistlY of Health, GSB NO 2257/95 (1997)(Mikus, Vice-Chair) OPSEU (Turcotte)
and Ministry of the Solicitor General and Correctional Services GSB No 2196/97
(MarszewskI, Vice Chair) Re International Waxes Ltd And Oil, Chemical and Atomic
Workers International Union supra Re Ontario Hydro and Ontario Hydro Employees
Union, Local 1000 et al. (1983) 147 D,L.R, (3d) 210 (Ont. C A) Re Consolidated-
Bathurst Packaging Ltd (St. Thomas Division) and International Wooclliorkers of
America, Local 2-337 (1981) 1 LAC (3d) 10 (Adams) The Umon argues that SInce
the rIght to apply to restrIcted competItIOns creates a substantIve rIght, any provIsIOn
whIch purports to take away the rIght to arbItrate a dIspute over that rIght IS VOId under
SectIOn 7(3) of CECBA. AccordIngly It contends dIsputes over the rIght to apply to
restrIcted competItIOns under ArtIcle 20.2 3 are arbItrable
In terms of the standard of arbItral reVIew the Umon contends that the standard
should be hIgher than the "bad faith" standard applIed to unclassIfied employees under
OPSEU (McIntosh) supra It submIts that the language used In ArtIcle 20.2 3 - the rIght
to apply to restrIcted competItIOns - IS broader than the lImIted rIghts unclassIfied
employees have under ArtIcle 6 and would therefore encompass more of the prIncIples
set out In ArtIcle 6 It contends that even though the surplus employees no longer have
semorIty they are entItled to have theIr qualIficatIOns fully and fairly assessed and to
partIcIpate In competItIOns free from fatal flaws It argues that when the purpose of the
12
provIsIOn IS consIdered - to provIde surplus employees wIth the opportumty to return to
the publIc servIce and regaIn theIr semorIty - a broader standard of reVIew IS reqUIred,
Decision
1 Arbitrability
Based on the case law cIted, the questIOn of arbItrabIlIty of ArtIcle 20 2 3 depends
on whether that provIsIOn creates a substantIve rIght on behalf of employees who elect
pay In lIeu of notIce Whether the IndIVIdual IS an "employee" at the tIme of the
grIevance or at the tIme the claim arose IS not determInatIve because a collectIve
agreement may confer a rIght or a benefit on a non-employee that IS enforceable through
the grIevance arbItratIOn procedure See Re Blouin DrJM'all Contractors Ltd and United
Brotherhood of Carpenters and Joiners of America, Local 2486 supra cIted In Re
HoneJM'ell Ltd And United Automobile Workers Local 80 supra. What matters IS
whether the collectIve agreement creates a substantIve rIght and that IS a matter of
contract InterpretatIOn,
For a number of reasons, I conclude that the last sentence of ArtIcle 20.2 3 creates
a substantIve rIght In surplus employees who elect pay In lIeu to apply to restrIcted
competItIOns for a perIod of twenty-four months
By ItS terms, ArtIcle 20.2 3 states that employees who elect pay In lIeu "wIll be
elIgIble to apply for restrIcted competItIOns " By defimtIOn, a restrIcted competItIOn IS
lImIted to current classIfied cIvIl servants or unclassIfied staff workIng In the OPS dUrIng
13
the postIng perIod, AccordIngly the abIlIty to apply to restrIcted competItIOns IS an
abIlIty whIch non-employees do not enjoy It IS a real, tangIble, substantIve benefit.
That the partIes Intended It to be meamngful, as opposed to gratUItous, IS eVIdent
from the fact that It was bargaIned, It was a negotIated benefit. It was part of the
package of benefits negotIated to encourage employees to accept pay In lIeu Instead of
remaInIng to seek dIsplacement or redeployment opportumtIes It also takes on added
meamng In lIght of ArtIcle 20.2 5 Under that provIsIOn, If an employee who accepted
pay In lIeu successfully competes for a posItIOn WIthIn the twenty-four month perIod, hIS
or her prIor contInUOUS servIce IS restored, GIven the Importance of an employee's
contInUOUS servIce date under the collectIve agreement and In the OntarIo publIc servIce,
the opportumty to compete and return to the publIc servIce WIthIn the twenty-four month
perIod IS a substantIal and substantIve benefit.
The fact that the words "elIgIble to apply" are used rather than "rIght to apply"
makes no materIal dIfference StatIng that employees who elect pay In lIeu "wIll be
elIgIble to apply" IS no dIfferent than statIng that they have the rIght to apply
AccordIngly I conclude that the rIght to apply to restrIcted competItIOns
contaIned In ArtIcle 20.2 3 IS a substantIve rIght In the employee who accepts pay In lIeu
whIch may be asserted agaInst the Employer As such, a dIspute over It creates a
"dIfference between the partIes arIsIng from the InterpretatIOn, applIcatIOn, admInIstratIOn
14
or alleged contraventIOn of thIS Agreement " as set forth In ArtIcle 22 and SectIOn 7(3)
of CECBA
I also conclude that the first sentence of ArtIcle 20.2 3 does not read out the
grIevance procedure Counsel for the Employer acknowledged that an employee's claims
under ArtIcle 53 or 78 and ArtIcle 20 3 or paragraph 4 of AppendIx 9 were subject to the
grIevance arbItratIOn, but argued that the abIlIty to apply to restrIcted competItIOns was
not. Counsel sought to dIStIngUISh the former benefits as arISIng whIle the IndIVIdual was
stIll an actIve employee whIle the latter benefit arose thereafter She also argued that It
was a gratUItous benefit. I cannot agree For the reasons already stated, the rIght to apply
to restrIcted competItIOns IS a real, not a gratUItous, benefit. I also see no dIstInctIOn
based on tImIng, Both separatIOn and termInatIOn benefits accrue upon resIgnatIOn, not
before It. AccordIngly all of the benefits conferred In ArtIcle 2023 arIse after the
employee resIgns
I also conclude that far more explIcIt language would be needed to decIde that the
partIes' meant to exempt grIevance arbItratIOn from the rIghts provIded under ArtIcle
2023 Re Corp of the City of Windsor and International Association of Firefighters,
Local 455 supra, Re International Waxes Ltd And Oil, Chemical and Atomic Workers
International Union, supra
But even If ArtIcle 2023 could be read so as to exclude from arbItratIOn the
rIghts provIded under ArtIcle 20.2 3 such an exclusIOn would be vOId under SectIOn 7(3)
15
of CECBA The case law cIted, IncludIng GSB case law clearly establIshes that where a
collectIve agreement creates a substantIve, assertIble rIght agaInst the employer then "any
provIsIOn In the agreement whIch blocks the resort to arbItratIOn to determIne the rIght
would be vOId as contrary to [then]s 37(1) [of the Labour RelatIOns Act; now s 48(1)]"
Re Ontario Hydro and Ontario Hydro Employees Union, Local 1000 et al. supra at
p.222 Then s 37(1) of the OntarIo Labour Relations Act IS substantIally sImIlar to s 7(3)
of CECBA Accord, Re Toronto Hydro-Electric System and Canadian Union of Public
Employees Local 1 (1980) 111 D,L.R. (3d) 693 (Ont. DIV Ct) Re C onsolidated-
Bathurst Packaging Ltd (St. Thomas Division) and International Woocfu,orkers of
America, Local 2-337 supra
In OPSEU (Turcotte) supra, Vice-Chair MarszewskI determIned that the GSB
had JUrISdIctIOn to determIne If a probatIOnary employee has been dIscharged for just
cause or termInated due to a bona fide release, despIte provIsIOns In the collectIve
agreement whIch read "[a]ny probatIOnary employee who IS dIsmIssed or released shall
not be entItled to file a grIevance" and "[f]or greater certaInty It IS understood that
nothIng In ArtIcle 2 1 1 [whIch reqUIres just cause for dIscIplIne and dIsmIssal of
employees] confers on a probatIOnary employee any rIght to grIeve or arbItrate hIS or her
dIsmIssal" Vice-Chair MarszewskI found that the collectIve agreement conferred on all
employees an unqualIfied substantIve rIght not to be dIsmIssed wIthout just cause, and
that a procedural provIsIOn regardIng access to the grIevance arbItratIOn procedure could
not constItute a bar to and defeat a substantIve rIght. (p 22)
16
Vice-Chair Mikus In OPSEU (Pietroban) supra, made a sImIlar rulIng, In that
case, the Employer argued that a Memorandum of Agreement In regard to GO-Temp
employees dId not Include the grIevance arbItratIOn provIsIOn, Vice-Chair Mikus
determIned that the Memorandum of Agreement, as a collectIve agreement, could not
have excluded the grIevance arbItratIOn procedure She further ruled at pp 8-9 that
"[e]ven If It was theIr IntentIOn to exclude the grIevance procedure from the
Memorandum of Agreement, theIr IntentIOns cannot supersede the provIsIOns of the Act."
AccordIngly In thIS case I conclude that ArtIcle 20 2 3 confers a substantIve rIght
In employees who elect pay In lIeu to apply for restrIcted competItIOns for a perIod of
twenty-four months, and that It IS a rIght assertIble agaInst the Employer I also conclude
that neIther ArtIcle 20.2 3 nor ArtIcle 22 precludes the arbItratIOn of "dIfferences" over
that rIght, but that even If they dId, they could not be enforced In lIght of SectIOn 7(3) of
CECBA
2. Standard of Review
For the reasons set forth below I conclude that the standard of reVIew should be the
"bad faith" standard applIed to unclassIfied employees
HistorIcally unclassIfied employees had no rIghts under then ArtIcle 4 PostIng and
FIllIng of VacanCIes or New PosItIOns [now ArtIcle 6] Then, In the 1992-1993 collectIve
agreement, unclassIfied employees were gIven lImIted rIghts under ArtIcle 4 1 and 4 4
specIfically the rIght to have theIr applIcatIOns acknowledged and tIme off wIth no loss
17
In pay for an IntervIew Vice Chair DIssanyake In OPSEU (McIntosh) supra at p 20
determIned that these provIsIOns "explIcItly recogmze that unclassIfied employees wIll
have a rIght to partIcIpate Injob competItIOns under artIcle 4 "
In my VIew the rIght of unclassIfied employees to partIcIpate In job competItIOns for
unclassIfied employees and the rIght to apply to restrIcted competItIOns In ArtIcle 20 2 3
are substantIally sImIlar The "rIght" contaIned In ArtIcle 20.2 3 IS not lImIted, as the
Employer contends, to the lIteral abIlIty to apply To so narrowly construe thIS provIsIOn
would render the rIght to apply whIch IS a substantIve rIght, largely Illusory When the
purpose of the provIsIOn IS consIdered - to provIde employees who are surplus sed and
elect pay In lIeu the opportumty to apply for restrIcted competItIOns and possIbly return to
the publIc servIce - then It must be determIned that the rIght Includes the rIght to
partIcIpate In such competItIOns
As wIth the unclassIfied employees, the rIght to apply to restrIcted competItIOns
cannot be rendered meamngless by bad faith conduct by the employer As Vice-Chair
DIssanayake concluded In McIntosh at pp 20-21
It IS not reasonable to conclude that the partIes would go to the trouble of
amendIng the collectIve agreement to facIlItate, and Indeed encourage (by
provIdIng for paid tIme off In ArtIcle 44), partIcIpatIOn by unclassIfied
employees In job competItIOns and at the same tIme permIt the employer
to render those provIsIOns meamngless by actIng In bad faith, The bad
faith conduct of the employer would unduly lImIt, and Indeed negate, the
rIghts of unclassIfied employees under artIcles 4 1 and 4 4 Those rIghts
would be rendered meamngless HavIng facIlItated and encouraged
partIcIpatIOn In job competItIOns, It must reasonably be Inferred that the
partIes would have envIsaged at the very least that those unclassIfied
employees who do partIcIpate wIll have theIr applIcatIOns consIdered by
the employer In good faith,
18
LIkewIse here, I conclude that the partIes would not have Included such a rIght In the
collectIve agreement and at the same tIme permIt the employer to render that rIght
meamngless by actIng In bad faith, At the very least, as concluded In McIntosh those
employees who elect pay In lIeu and apply to a restrIcted competItIOn dUrIng the twenty-
four month perIod are entItled to have theIr applIcatIOns consIdered by the employer In
good faith,
Although I am sympathetIc to the sItuatIOn of those surplus employees who desIre
to return to the publIc servIce, I do not belIeve theIr rIghts under ArtIcle 20.2 3 can be
equated wIth the rIghts of classIfied staff under ArtIcle 6 Instead, theIr rIghts are akIn to
those of unclassIfied employees and the same standard of reVIew should apply
AccordIngly I conclude and declare as follows
1 ArtIcle 20 2 3 creates a substantIve rIght In employees who elect pay In lIeu to apply
for restrIcted competItIOns for a perIod of twenty-four months
2 As a substantIve rIght, any "dIfferences between the partIes arIsIng from the
InterpretatIOn, applIcatIOn, admInIstratIOn or alleged contraventIOn" of the Agreement
are arbItrable under ArtIcle 22 and SectIOn 7(3) of CECBA
3 The arbItral standard of reVIew IS the "bad faith" standard applIed to unclassIfied
employees
Dated at Toronto thIS 8th day of May 2001
H'1/0rmtfJ(
RandI Hammer Abramsky Vice-Chair