HomeMy WebLinkAbout2000-1357.Policy Grievance.02-04-22 Decision
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IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
ASSOCIATION OF MANAGEMENT, ADMINISTRATIVE AND PROFESSIONAL
CROWN EMPLOYEES OF ONTARIO
(Policy Gnevance)
Grievor
- and -
THE CROWN IN RIGHT OF ONTARIO
(Management Board Secretanat)
Employer
BEFORE Paula Knopf Vice-Chair
FOR THE GREIVOR Michael Mitchell,
Counsel
Sack Goldblatt Mitchell
Barristers & Solicitors
Rob Smalley
Team Leader, Dispute Resolution
Association Of Management, Administrative and
Professional Crown Employees Of Ontano
2
Burke Moffat
Project Officer
Association Of Management, Administrative and
Professional Crown Employees Of Ontario
FOR THE EMPLOYER Leonard Marvy,
Senior Counsel
Legal Services Branch
Management Board Secretariat
Meredith Brown
Counsel
Legal Services
Management Board Secretariat
Linda Wendel
Co-Coordinator Union/Management Relations
Management Board Secretariat
Anna Hoad
Mediator
Policy & communications DIvIsion
Management Board Secretariat
FOR OPSEU Andrew Lokan
Counsel
Pallare Roland Rosenberg Rothstelnlop
Barristers & Solicitors
Timothy Hadwen
Counsel
Ontario Public Service Employees' Union
FOR PEGO Larry Robbins
Labour Consultant
Barrister & Solicitor
Dan Conte
President
Professional Engineers and Architects
of the Ontario Public Service
HEARING DATE January 9 and February 21, 2002
3
PRELIMINARY AWARD
This case Involves a grievance concerning the Interpretation of the
recognition clause In the collective agreement between AMAPCEO and ItS employer,
the Management Board Secretariat (MBS) The grievance asserts that the Employer
IS failing to Include or recognize employees or groups of employees under the
recognition clause of the collective agreement. The recognition clause reads,
PART I - RECOGNITION
1 The Government recognizes the Association of
Management, Administrative and Professional Crown
Employees of Ontario as the exclusive bargaining agent for a
bargaining unit composed of all Crown employees as defined
In section 1 of CECBA, 1993 who are Public Servants, who
were not Included In the SIX bargaining units described by the
Lieutenant Governor In Council In the classifications listed In
Order-In-Council 243/94 dated February 3, 1994, plus such
other classifications created after February 3, 1994 and
properly Included In the SIX units, save and except, persons
who exercise managerial functions or who are employed In a
confidential capacity relating to labour relations, or lawyers
and engineers who are employed In their professional
capacity For greater certainty, all employees In the
classifications listed In Order-In-Council 243/94 In respect of
the seventh bargaining unit, which list of classifications IS
attached as Schedule 1, all Go Temp employees, students
and Interns as provided for In Part VIII of Order-In-Council
243/94, and all other employees In any other similar classes
to those listed In the Order In Council In respect of the
seventh unit as may be established (save and except,
persons who exercise managerial functions or who are
employed In a confidential capacity relating to labour
relations, or lawyers and engineers who are employed In
their professional capacity) fall within the seventh bargaining
unit, together with any other Crown employees who are not
Included In the SIX bargaining units described by the
Lieutenant Governor In Council pursuant to CEBA, 1993
In a nutshell, the Employer's position IS that the AMAPCEO bargaining unit IS
defined by the OIC referred to In the recognition clause On the other hand,
AMAPCEO's position IS that the recognition clause creates a tag end bargaining unit
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which encompasses all employees who are not In the SIX bargaining units
represented by OPSEU Further, AMAPCEO argues that employees have been
Improperly excluded from the OIC and that the classifications covered by the
collective agreement Include more than those set out In Order-In-Counsel 243/94
and Issued by the Employer
Notice of these proceedings was given to PEGO ThiS IS partly
because after thiS grievance was filed, the Employer entered Into a voluntary
recognition agreement With PEGO that Included land surveyors AMAPCEO has
filed a challenge to that voluntary recognition agreement before the OLRB That
matter has been "stood down" pending resolution of thiS grievance In these
proceedings The Employer and AMAPCEO agree that thiS grievance may affect the
rights of the land surveyors and PEGO's bargaining rights Accordingly, there IS no
dispute between the parties that PEGO ought to be granted third party Intervener
status In thiS case PEGO has Indicated that It IS prepared to be bound by the award
In thiS matter
However, before the matter could proceed to a hearing on the merits,
the Employer raised the question of whether OPSEU should also be given notice of
these proceedings and an opportunity to seek status as an Interested third party
AMAPCEO opposed thiS, arguing that no OPSEU Interest would be affected by the
Issues raised In the grievance or the remedies being sought. In order to ensure
procedural and substantive fairness, these proceedings were then adjourned to
provide notice to OPSEU and to allow It the opportunity to consider whether It
wanted to seek status In thiS grievance Thereafter, OPSEU did attend on the date
set for resumption of the matter and sought status In these proceedings The
purpose of thiS preliminary award IS to determine that question
The historical context of thiS case IS Interesting and relevant. The
Ontario Public Service was originally organized by statute Into one bargaining unit
and was represented by OPSEU Reforms relating to crown employees and their
collective bargaining rights In the 1990's resulted In many changes which Included
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the separation of the one OPSEU bargaining unit Into SIX smaller units Around the
same time, It was recognized that a large number of people working within the public
service who had been labeled as "managerial" and excluded from collective
bargaining would not be excluded from a bargaining unit If the claSSIC definitions of
"employee" and "manager" were applied to them A decIsion was then made to
create a seventh bargaining unit of these administrative, managerial and
professional crown employees ThiS group IS now represented by AMAPCEO
AMAPCEO has launched thiS grievance to seek clarification and
resolution of the questions surrounding the recognition clause In the voluntary
recognition agreement between Itself and MBS The grievance seems to have been
triggered by the fact that the Employer IS allegedly leaving some classifications out
of the schedule of employees listed In Order-In-Council 243/94 which IS referred to In
the recognition clause The grievance also seems to have been triggered by the
creation of new classifications that MBS IS treating as non-unionized AMAPCEO
asserts that the purpose of thiS grievance IS to establish that the Employer cannot
create new classifications of employees that do not fall Within unionized
classifications AMAPCEO seeks a declaration that It has bargaining rights to
everyone In the Ontario Public Service who IS not properly covered In OPSEU's
original SIX bargaining units or who the parties have agreed belong elsewhere
AMAPCEO asserts that there IS no employee or classification that It IS seeking to
Include In ItS bargaining unit that would be entitled to be represented or covered by
OPSEU AMAPCEO claims that It IS seeking recognition of ItS right to represent all
employees who are not properly Included In OPSEU's SIX bargaining units In
essence, AMAPCEO seeks a declaration that It IS a "tag end" unit.
Counsel for AMAPCEO acknowledges that there may be some
classifications In the OPSEU classification scheme "at the very bottom of the
classes" that AMAPCEO now represents which are not now In the OPSEU
descriptions or bargaining units AMAPCEO promises that If these are properly
OPSEU classifications, It will not seek to represent them Instead, AMAPCEO IS
seeking the following declarations
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a Save and except with the agreement of the parties, the
AMAPCEO ih unit IS a "tag-end" unit - which Includes all
non-OPSEU employees, save and except those persons In
the professional units (lawyers and engineers) and those
excluded by statute,
b For certainty, all MCP classes (tops and bottoms), but not
necessarily the employees within them,
c That the Crown cannot create new classes that are non-
union,
d That the land surveyors are covered by the AMAPCEO
collective agreement;
e In the alternative, that certain classes are Included and have
to be listed because they are employees In them now paYing
dues to AMAPCEO
MBS's position on the merits of thiS case IS that AMAPCEO does not
have bargaining rights for "all other" crown employees who are not Included In
OPSEU's SIX bargaining units The Employer's position can be summarized as
follows
a The AMAPCEO recognition clause Includes only those
employees Included In OIC 243/94 as modified by
Schedule 1, similar classes to those In the modified list, and
similar Go Temp, students or Interns It does not Include
MCP classes which were not listed (whether tops or
bottoms) In the modified list to the OIC It does not Include
"Tier II" classes, subject to the VRA process It does not
Include new classes, unless they are similar to AMAPCEO
A new class IS not a part of AMAPCEO, only If It IS not similar
to OPSEU
b Only those MCP classes listed In the modified schedule 1
referred to In the AMAPCEO recognition clause are a part of
their unit.
c The Crown can create new classes of employees, WhiCh, If
the class IS not "similar" to OPSEU or "similar" to AMAPCEO,
do not automatically fall within the AMAPCEO unit. These
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employees would have the right to chose [SIC] whether they
wish to belong to a bargaining unit and If so which one
Accordingly, non-managerial, non-statutorily excluded Crown
employees can eXist who do not belong to a union
d The land surveyors are not covered by the AMAPCEO
collective unit
e The employees In classes which the employer claims are not
covered by the AMAPCEO recognition clause, and who have
been paYing dues, are not covered simply because of that
fact. The employees In those classes either fall within the
recognition clause definition or they do not.
Therefore the Employer IS vigorously opposing thiS grievance It also argues that the
Issues raised by the case dictate that OPSEU should be present and have status at
the hearing of thiS grievance
AMAPCEO opposes the granting of status to OPSEU, arguing that It IS
not seeking to take anything away from OPSEU and that nothing In thiS case could
negatively Impact upon OPSEU's rights
The An::Jument of the Parties ReQardinQ Third Party Status for OPSEU
OPSEU'S POSITION
Counsel for OPSEU asserts the right to third party status In these
proceedings arguing that thiS dispute may Involve or affect OPSEU's Interests It
was argued that Issues raised by AMAPCEO and MBS could Involve a termination of
OPSEU's rights For example, OPSEU's bargaining units may have classifications
that could fall within the MCP classes or descriptions or that may more closely
resemble OPSEU than AMAPCEO It was argued that the determ Inatlon of who IS
properly within the descriptions can only be done with OPSEU's participation
because the outcome will affect the union's representational Interest.
8
OPSEU agrees with AMAPCEO that the government as employer
cannot create new classifications that are non-unionized Therefore, OPSEU would
seek a similar declaration that IS being sought by AMAPCEO In this regard
However, OPSEU seeks status to ensure that such a declaration does not result In
AMAPSEO gaining exclusive representation rights for those new classes
Further, counsel for OPSEU pOints out that the creation of the
bargaining units for Crown employees were the result of discussions between
OPSEU and MBS It became apparent from the submissions set out by the parties
that the circumstances surrounding the evolution and creation of the SIX OPSEU
bargaining units and the seventh unit represented by AMAPCEO will be part of the
eVidentiary foundation of AMAPCEO's case Negotiating history and documentation
were Identified by AMAPCEO as part of ItS case Therefore, OPSEU submits that It
can offer "special knowledge" to these proceedings and has an Interest In the results
Further, OPSEU argues that the Issue of the land surveyors raises
questions about whether thiS group properly belongs Within the OPSEU bargaining
unit. Therefore OPSEU claims an Interest In thiS Issue as well
OPSEU takes no comfort from AMAPCEO's assurance that the
grievance may not affect OPSEU or ItS rights OPSEU argues that It could have a
claim on the Tier 2 Incumbents who are found eligible for collective bargaining
Because thiS dispute was said to "touch upon" the rights and Interests of the OPSEU
bargaining unit, counsel for that union argued that the proper approach would be to
grant OPSEU third party status at thiS time
Counsel for OPSEU relies on the decIsion of the Ontario Court of
Appeal In CUPE v Canadian Broadcasting Corporation et ai, 70 DLR (4d) 175,
affirmed 91 DLR (4d) 767 and the Supreme Court's decIsion In the same matter at
[1992] 2 SCR 7 It was said that thiS case supports OPSEU's position that status IS
"essential" In thiS case because the Employer has a "limited Interest" In the position
that OPSEU IS advocating and OPSEU's collective agreement will have to be
9
Interpreted and applied to resolve AMAPCEO's grievance OPSEU also relies on the
following cases Ontano Hyrdo and Ontano Hydro Employees Umon (1990),
17 L.A.C (4th) 212 (P C Plcher) and Scarborough General Hospital and CUPE,
Local 1487 (1999),79 L A.C (4th) 246 (L M Davie)
MBS's POSITION
The position of Management Board IS that a "crucial" Issue In this case
IS whether AMAPCEO IS a tag end unit pursuant to the recognition clause It was
submitted that the determination of that question will Involve analyzing Management
Board's voluntary recognition agreement with AMAPCEO as well as an Interpretation
of OIC 243/94 which ties together both OPSEU and AMAPCEO In the creation of the
seven bargaining units Further, MBS IS arguing that AMAPCEO IS not a tag end unit
which would automatically be entitled to represent any new classes not already
covered by OPSEU or AMAPCEO Therefore, It was argued that since OPSEU could
seek bargaining rights for such groups, that union should have status In these
proceedings to assert ItS Interests In that aspect of the analyses
MBS also argues that OPSEU may have an Interest In the Issue of
crown employees who are not excluded and who do not belong to a union For
example, there may be people In the Tier 2 group who may be entitled to be
bargaining unit members but who may choose not to become part of AMAPCEO
Therefore, It was argued that OPSEU has an Interest In thiS Issue because of the
question of AMAPCEO's "tag end" entitlement.
Finally, It was submitted that the nature of these proceedings suggests
the Importance of Including OPSEU as a third party with status It was submitted that
since thiS case IS being heard by a vice-chair of the Grievance Settlement Board, the
determination of AMAPCEO's collective agreement and the rights of MBS will have a
significant If not authoritative effect on OPSEU's Interests OPSEU would then have
to show "exceptional circumstances" In any other proceeding to be able to challenge
the determinations made In thiS case Therefore, It was subm Itted that It would be
10
better to allow OPSEU to participate and be bound by these proceedings In order to
bring finality and resolution to the Important Issues raised by the grievance The
Employer relies on the decIsion between Blake et al and Amalgamated Transit Umon
and Crown In Right of Ontano, GSB decIsion 1276/87 etc decided by 0 B Shlme
May 3, 1988
AMAPCEO'S POSITION
AMAPCEO opposes the granting of third party status to OPSEU
Counsel for AMAPCEO concedes that Management Board's counsel has raised
some legitimate questions concerning OPSEU's rights However, It was argued that
those questions can and should be resolved In other proceedings, not thiS one It
was stressed that there IS not one Job or class that AMAPCEO IS seeking that could
affect OPSEU's rights or Interests AMAPCEO dismisses OPSEU's attempt to assert
rights over the land surveyors as something that can or should be easily determined
In a separate hearing AMAPCEO claims that OPSEU has no basIs raising thiS
matter at thiS time given that MBS has entered Into a voluntary recognition agreement
with PEGO for that group and AMAPCEO IS challenging that before the OLRB
without any prevIous Intervention or Interest being expressed by OPSEU That IS the
proceeding being held down pending the outcome of thiS grievance Therefore,
AMAPCEO suggests that If OPSEU has any real claim over thiS group, that matter
could and should be resolved In a preliminary fashion before the rest of thiS grievance
proceeds on ItS merits (OPSEU asserts that until the proceedings In thiS case, It was
unaware of the Issue of the land surveyors and AMAPCEO's proceedings before the
OLRB)
AMAPCEO also argues that If OPSEU IS granted status on the basIs
that It may have an Interest In newly created positions that OPSEU may want to
organize or represent, then any other union would or should be given similar status,
such as CUPE or even the CAW It was argued that the desire to organize a
potential group that does not currently eXist should not give OPSEU or any other
union status In a grievance that seeks to clarify the scope of a recognition clause
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AMAPCEO also stresses that It has launched this grievance to rectify
an alleged "mischief" being created by Management Board's exclusion of certain
groups In the OIC generated by the recognition clause AMAPCEO does not want
thiS case to be perceived as a claim for any OPSEU classes or groups
AMAPCEO also argues that If any Issues should arise as to whether a
particular job or class belongs within AMAPCEO or OPSEU, that should or could be
resolved on the basIs of clear, concrete facts, outside of thiS particular grievance
process It was stressed that the grievance should not become a forum to decide the
dividing line between OPSEU and AMAPCEO It was said that there are other
mechanisms available to the parties should the need arise
AMAPCEO argues that the current authoritative cases on the status
Issue are Weston Bakenes Ltd and Milk and Bread Dnvers, Dairy Employees,
Caterers and Allied Employees, Local 647 (1999),79 L.A.C (4th) 189 (0 V Gray),
Toronto (City) v Toronto CIVIC Employees Umon, Local 416 (2001), OLAA No 599
(J Johnson) and Ste/co Inc (Hilton Works) and Umted Steel Workers of Amenca,
Local 1005, (2001) OLAA No 308 (H D Brown) It was also submitted that these
cases dictate that Interveners are obliged to be bound by the results of arbitrations at
which they have sought status In the event that OPSEU IS given status, It was
submitted that It should be made to be bound by the results as a condition of
participating In these proceedings
DECISION
One should begin with the legal analysIs of the standing Issue The
question of third party status In a grievance arbitration IS both a natural Justice and a
labour relations Issue On a basIc level, grievance arbitration IS designed to resolve a
dispute under a collective agreement between the two parties to that contract.
However, If the determination of that grievance will have a significant effect upon
another party, natural Justice demands that the third party be given status and appear
12
to be able to protect Its position In those proceedings ThiS concept was set out In
the CUPE and cae case, supra That was a JUrisdictional dispute In which the rights
of three unions were at stake The Court of Appeal said at page 177
My thinking starts with a practical, common-sense compulsion to
put all these parties In one room, before one tribunal, to obtain one
ruling on their differences Upon analysIs I find that legal precedent
supports thiS view
The practical rationale cannot be better put than In the majority
deCISion In Re Toronto (MUniCipality) and CUP E , Local 43
(1989), 5 L.A C (4th) 404, 14 C L.A S 29 The grievance was by
Local 43 of CUPE complaining that work to which they were entitled
was being assigned to Local 79 of CUPE Local 79 wanted status
before the arbitration board and Local 43 objected In their
reasons, the majority said at pp 410-1
The cases offer very little gUidance on the
consequences of a party being given status It was
pOinted out In argument before us, that It would be
unfair for Local 79 to have status In these proceedings
and, If Local 43 were to succeed, process a similar
grievance under their collective agreement.
The purpose of arbitration IS to provide an
expeditious settlement of disputes between
employees and unions concerning the Interpretation
of their various agreements It IS a private system that
the parties commit themselves to (albeit through
legislative direction) It IS Intended to be practical,
accessible and remedial
Here we have one employer and two unions,
each of which IS bound to such a system of dispute
settlement with that common employer It IS
academically correct, but totally Impractical, to say
that In disputes such as the one before us, the board
should deny status to the other union
Page 179
Continuing with a common-sense analysIs, we have a
two-party dispute In which the employer has limited
13
Interest and a third party's agreement has been
Interpreted, leading to an award that effectively directs
the transfer of work assignments while the Individuals
who suffer are left to pursue grievances under their
own collective agreements In hope of receiving a
conflicting decIsion In the alternative, they may refer
the Issue to the Canada Labour Relations Board
under s, 65(1), the language of which does not clearly
embrace this type of dispute We were told that the
board does, In fact, entertain such referrals and no
Inference should be taken from these reasons as to ItS
JUrisdiction to do so I only observe that there IS no
clear legislative path to resolution of these
overlapping disputes though practicality In day-to-day
labour relations demands that there be one In fact,
we were referred to a number of arbitration awards
adopting some form of Involvement by non-parties to
an agreement In similar Situations, Indicating that,
whatever the legal obligation, thiS IS the usual
practice
Page 181
Arbitrators are working within a statutory framework to
assure that employers and employees treat one
another fairly within the context of their agreements,
that disputes are efficiently resolved and that labour
relations do not break down through the alternative of
protracted court proceedings Their awards can
become judgments of the Federal Court when filed
pursuant to s 66 of the Canada Labour Code They
must be fair and should not be restricted to hearing
only persons with a strict legal Interest.
In my View, It was unfair and constituted a failure of
natural Justice to deal with the employment
opportunities of the CUPE and NABET union
members, In the circumstances of thiS case, In the
absence of notice and an opportunity to seek
Involvement In the decIsion-making process
The Supreme Court of Canada affirmed thiS decIsion, supra, holding that It IS a
denial of natural Justice to fall to give notice to a union when the result of the
grievance arbitration could have "a significant effect" on that union
14
In the Ontano Hydro case, the Issue of third-party status arose when
one union brought a grievance that raised an Issue of the effect of the recognition
clause VIS a VIS another union In that case, arbitrator Pamela Plcher found that
some of the positions In the arbitration arguably fell within the bargaining unit defined
In the other union's collective agreement. Therefore, If the grieving union succeeded
In ItS case, the other union would lose positions from ItS bargaining unit. Because of
the long-standing relationship with the Employer, the clearly definable rights were
held to be of substantial legal Interest which were Jeopardized by the grievance
Therefore, relYing on the cae case, status to participate In the grievance was
granted
These cases make some Issues In the case at hand clear and leave
other Issues not so easily resolved If AMAPCEO's grievance had the potential of
directly affecting the Integrity of OPSEU's bargaining or certain classes within that
unit, OPSEU's right to participate would be unquestioned according to the dictates of
natural Justice That IS precisely why PEGO has been given uncontested status to
participate In the proceedings because of AMAPCEO's claim to the land surveyors
But OPSEU vehemently asserts that nothing In thiS grievance can or will directly
affect OPSEU's rights, Interests or the Integrity of ItS bargaining unit
These proceedings and the resulting award can, to some extent, be
controlled by thiS Vice-Chair to ensure that thiS process could remain within the
scope of AMAPCEO's promise that nothing In these proceedings could directly affect
any eXisting OPSEU positions or classes It IS also true that other avenues eXist that
allow Management Board and OPSEU or AMAPCEO resolve any JUrisdictional
disputes that could arise In the future about whether a position properly fits within the
AMAPCEO or OPSEU bargaining unit. It IS also clear from OPSEU's submissions
that It never Intended thiS grievance to become a JUrisdictional dispute between
OPSEU and AMAPCEO In that way, thiS case IS distinguishable from the cae and
Ontano Hydro cases
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The conceptual difficulty with this case IS that AMAPCEO's grievance
seeks to define ItS own bargaining rights However, those rights are, by definition,
determined In part by another bargaining units recognition clause Article 1 of
AMAPCEO'S voluntary recognition agreement with MBS defines AMAPCEO's
bargaining unit In part as crown employees "who are not Included within the SIX
[OPSEU] bargaining units" The definition IS much more complex than that. But part
of the analysIs of thiS case will Involve a determination of the effect of thiS language
Can thiS then be done without OPSEU being given status In these proceedings?
ThiS case IS, In ItS essence, a labour relations arbitration designed to
resolve and normalize the rights and responsibilities of the Employer and the
AMAPCEO bargaining unit. I accept the approach taken by the collective agreement
In the cae case wherein It was said
Arbitrators are working Within a statutory framework to assure that
employers and employees treat one another fairly Within the context
of their agreements, their disputes are efficiently resolved and that
labour relations do not break down through the alternative of
protracted court proceedings They must be fair and should not
be restricted to only hearing persons With a strict legal Interest.
Therefore, while It may be academically or technically possible to conclude that thiS
grievance can be determined Without granting OPSEU status, the effect of that
would be counter-productive to the purposes of labour relations Further, In
essence, AMAPCEO's grievance asserts that ItS bargaining unit IS a tag end unit. If
that were the case, then thiS grievance would be a fight only between AMAPCEO
and Management Board because It would determine their relative rights However,
the Issues raised by the Employer question whether AMAPCEO's bargaining unit IS
Indeed a tag end unit. The Employer's defence to the grievance raises Issues With
regard to the OPSEU bargaining unit and It therefore becomes In OPSEU's Interest
to argue whether AMAPCEO's bargaining unit IS a tag end unit or not. ThiS gives
OPSEU a real and substantial Interest In the question of whether AMAPCEO's
bargaining unit IS a tag end unit under the scheme of labour relations between these
16
three parties Because the question of tag end status IS the fundamental question In
this case, It would be Improper "to put the cart before the horse" and deny OPSEU
status before It IS determined whether or not AMAPCEO's bargaining unit IS a tag
end unit.
The Issues In this case also raise fundamental questions about the
scope of AMAPCEO's bargaining rights The answer to the grievance brings Into
play questions concerning the creation and the scope of the OPSEU bargaining
rights and ItS SIX bargaining units It IS difficult to Imagine how the facts could be
examined or their Impact determined Without the participation of OPSEU as a party
Further, the Issue of whether AMAPCEO's bargaining unit IS a tag end unit may have
Impact on the scope of the SIX other bargaining units I agree With AMAPCEO that
status should not be given on the basIs that OPSEU may Wish to assert claims over
new, non-unionized groups If any union has a claim to those groups, OPSEU may
have no better claim than any other Therefore, It would make no sense to grant
status In an arbitration on the basIs of such potential or tenuous claims But the
basIs of OPSEU's right to participate flows from the essence of AMAPCEO's
grievance It claims ItS bargaining unit covers anyone not Included In the SIX OPSEU
bargaining units The determination of that question brings thiS arbitration Into a
direct analYSIS of the OPSEU bargaining units and their scope To make a decIsion
about those Issues Without OPSEU present as a party would not only deny OPSEU
natural Justice, It would also create unnecessary labour relations difficulty The
recital of Issues raised by AMAPCEO's grievance shows some significant
differences between AMAPCEO and OPSEU over certain groups of employees
Including OPSEU In these proceedings will resolve those questions for the Employer
and these two unions Excluding OPSEU from the proceedings allows the possibility
that It could launch a new case In the future that may well be greatly Influenced by
these results, but would nonetheless engage the Employer In further protracted
proceedings Therefore, for all these reasons, It makes labour relations sense and IS
consistent With the concepts of natural Justice to grant OPSEU third party status In
thiS case
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Having said all thiS, there IS a note of caution that must be stated This
IS AMAPCEO's grievance The grievance was launched to clarify the scope of
AMAPCEO's bargaining unit and to determine If It IS a tag end unit and the
consequences that flow from such a finding ThiS shall not become a JUrisdictional
dispute where the proceedings bog down Into Intricate enquIries over whether one
classification falls better within the OPSEU or the AMAPCEO unit. There are other
avenues for such factual and legal analyses
Finally, the terms of OPSEU's participation need to be addressed
There IS a split In arbitral authority over whether an arbitration board has the power
or the JUrisdiction to bind an Intervening third party union In a grievance arbitration
The Scarborough General Hospital case suggests not, whereas the Stelco, Western
Bakenes and City of Toronto cases, supra, suggest otherwise The latter cases are
the most recent and are based on the concept that a party relYing on the rules of
natural Justice to attain status should also be required to assume the "usual and
reasonable burdens of that status" (See Western Bakenes at page 202 )
Specifically, one of the burdens of achieving party status In a proceeding IS that one
IS bound by the results of those proceedings
It IS not necessary In thiS case to resolve the arbitral dispute about
whether third parties can or should be bound by the arbitration constituted under the
original grievance In the case at hand, there IS a compelling reason to consider that
OPSEU must be bound by these proceedings ThiS case has been launched by a
grievance at the Grievance Settlement Board Unlike arbitrators sitting In private
arbitrations In the cases cited above, a Vice-Chairman of a statutory tribunal IS
hearing thiS case ThiS means that a decIsion rendered In thiS case has a profound
Impact not only on the direct litigants In these proceedings, but upon crown
employees as a whole The words of the Blake decIsion, supra, are very a propos
In the private sector ad hoc boards of arbitration have a
separate and distinct capacity to decide each case on ItS own
merits Recognizing that Individual, but different, decIsions on the
same pOint or Issue may create confusion, arbitrators have
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balanced the Interests of Individual decIsion making with
predictability by generally adopting a policy that they will not depart
from earlier decIsions unless such decIsions are manifestly In error
But the Grievance Settlement Board IS one entity - It IS not a series
of separately constituted boards of arbitration Under Section 20(1)
of The Crown Emplovees Collective Barqalnlnq Act !here IS "a
Grievance Settlement Board - that IS, one Board Under
Section 20(4) the Grievance Settlement Board may Sit In two panels
and under Section 20(6) a decIsion of the majority of a panel IS "the
decIsion" of the grievance Settlement Board
Thus each decIsion by a panel becomes a decIsion of the Board
and In our opinion the standard of manifest error which IS
appropriate for the private sector IS not appropriate for the
Grievance Settlement Board The Act does not give one panel the
right to overrule another panel or to Sit on appeal on the decIsions
of an earlier panel
As one entity, a decIsion by the Grievance Settlement Board through a Vice-Chair IS
a decIsion affecting thiS whole labour relations community Therefore It may not be
necessary to make OPSEU's participation contingent upon ItS agreeing to be bound
by the result. It may be that OPSEU IS practically and legally bound by the result In
accordance With the Blake decIsion whether It participates In these proceedings or
not. Therefore, In accordance With the principles In the Blake decIsion and
consistent With concepts set out In Ste/co, Western Bakenes and City of Toronto
cases, supra, I conclude that there IS JUrisdiction to order OPSEU to be bound by the
result In thiS proceeding as a condition to their participation Given the circumstances
of thiS case, It IS appropriate to do so However, to avoid any JUrisdictional
uncertainty In the future, since OPSEU has sought to attain status In these
proceedings, It behooves OPSEU to also agree to be bound by the result.
Accordingly, I order that OPSEU may intervene in these proceedings as a
party upon its delivery to MBS, AMAPCEO and PEGO of a written undertaking
and an agreement that OPSEU will be bound by the decision in this matter in
the same manner and to the same extent that the other parties are bound
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Having made these determinations, the case will now proceed to a
hearing on Its merits on the dates previously arranged
Dated at Toronto, thiS 22nd day of April, 2002
Paula Knopf, Vice-Chair