HomeMy WebLinkAbout2002-1510.Union Grievance.02-12-04 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
~-,...
Suite 600 Bureau 600 Ontario
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GSB# 151 0/02
UNION#2002-0999-0021
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano PublIc ServIce Employees Umon
(Umon Gnevance) Grievor
- and -
The Crown m RIght of Ontano
(Management Board Secretanat) Employer
BEFORE Richard Brown Vice-Chair
FOR THE UNION Richard Blair
Ryder Wnght Blair & Doyle
BarrIsters and SOlICItorS
FOR THE EMPLOYER Kelly Burke
Semor Counsel
Management Board Secretanat
HEARING October 18 & November 18 2002
2
DECISION
ThIS umon gnevance IS about hohday compensatIOn for full-tIme, classIfied
employees who were desIgnated to provIde essentIal or emergency servIces
dunng the most recent OPSEU strike The work stoppage lasted
approXImately eIght weeks and spanned two hohdays Good Fnday and
Easter Monday There IS no dIspute about the component of compensatIOn
that IS payment for work done on a hohday Employees who worked on such
a day were paid for theIr tIme, at tWIce the normal rate of pay, as the partIes
agree they should have been The dIspute IS about the other component of
hohday compensatIOn the one floWIng more dIrectly from the hohday Itself
and not based upon work performed that day
In tlus award, I consIder the general rules whIch detennIne the
apphcatIOn of the 1999-2001 collectIve agreement to employees perfonnIng
essentIal and emergency serVIces dunng the work stoppage, leavIng for later
consIderatIOn how those rules apply to the specIfic provIsIOns In the
agreement relatIng to hohdays
I
The umon contends all classIfied employees desIgnated as essentIal or
emergency, regardless of whether they worked on Good Fnday or Easter
Monday, are entItled to compensatIOn, In the form of a day's payor a paid
day off, In recogmtIOn of each of these days For each hohday, some
classIfied employees provIdIng essentIal or emergency servIces receIved a
full day's pay, but others were paid for only part of a day, and stIll others
denved no benefit at all from the hohday
The employer's treatment of employees IS best described by dIVIdIng
them Into three broad categones The first IS compnsed of essentIal
3
employees who contInued to work theIr full, pre-strikes hours dunng the
two-week pay penod whIch Included a hohday The treatment of these
employees can be Illustrated by reference to Good Fnday It fell on March
29, at the end of a pay penod. Employees workIng theIr regular hours
throughout thIS penod got a day's pay In recogmtIOn of the hohday, wIthout
reference to whether they worked that day For example, an employee, who
had worked an eIght -hour day before the strike, receIved eIght hours'
vacatIOn pay for Good Fnday, Ifhe or she worked eIght hours on each of the
nIne days precedIng the hohday, for a total of 72 hours In the pay penod.
The employer concedes these employees were entItled to compensatIOn In
recogmtIOn of the hohday
As to employees In the other two categones, the employer asserts they
were not entItled to compensatIOn and all payments made were gratUItous
The second category IS compnsed of essentIal employees who worked less
than theIr regular hours dunng a pay penod wIth a hohday They had theIr
hohday pay pro-rated. For example, an employee, who had worked an eIght-
hour day before the strike, or 72 hours over nIne days, receIved four hours'
hohday pay for Good Fnday, Ifhe or she worked 36 hours In the nIne days
precedIng the hohday
Emergency employees constItute the tlurd category TheIr entItlement
to hohday pay was determIned by reference to the number of hours worked
dunng the four days precedIng the hohday and the four folloWIng It, not by
reference to total hours worked dunng a pay penod. For example, an
employee, who before the strike worked eIght hours a day from Monday to
Fnday, was paid for eIght hours for each hohday, Ifhe or she worked eIght
hours on the four days precedIng Good Fnday and on the four days
folloWIng Easter Monday If the same employee had worked four hours a
4
day throughout these eIght quahfYIng days, he or she would have receIved
four hours' pay In recogmtIOn of each hohday
II
I was referred to the folloWIng sectIOns of the Crown Employees Collectlve
Bargaznzng Act, 1993 (CECBA) deahng wIth essentIal and emergency
servIces
30 In thIS part,
"essentIal servIces" means servIces that are necessary to enable the
employer to prevent,
(a) danger to hfe, health or safety,
(b) the destructIOn or senous detenoratIOn of machInery, eqUIpment or
premIses,
(c) senous envIromnental damage, or
(d) dIsnlptIOn of the admInIstratIOn of the courts or of legIslatIve
draftIng
"essentIal servIces agreement" means an agreement between the
employer and trade umon that apphes dunng a strike or lockout and
that has,
(a) an essentIal serVIces part that provIdes for the use, dunng a strike
or lockout, of employees In the bargaInIng umt to provIde essentIal
servIces
(b) an emergency serVIces part that provIdes for the use, dunng a
stnke or lockout, of employees In the bargaInIng umt, In addItIon to
those In clause (a), In emergencIes
40 (1) Dunng a strike or lock-out, the employer IS entItled to use, to
provIde essentIal servIces, such employees In the bargaInIng umt as
are necessary as provIded In the essentIal servIces part of the essentIal
servIces agreement
5
(2) The employer shall notIfy the employees who, under the essentIal
servIces part of the essentIal servIces agreement, the employer IS
entItled to use under subsectIOn (1) dunng a strike or lock-out
(3) Employees who have been not~fied by the employer or trade unlOn
that the employer lS entltled to use them under subsectlOn (1) may not
strzke and may not be locked out
41 (1) In an emergency dunng a strike or lock -out, the employer IS
entItled to use such employees as the emergency serVIces part of the
essentIal serVIces agreement provIdes for
(2) Employees who have been not~ed that the employer lS entltled to
use them under subsectlOn (1) and wlshes to do so may not strzke
whzle the employer lS so entltled and so wlshes (emphasIs added)
Under tlus statutory framework, the partIes executed an agreement,
dated September 20,2001, entItled CondItIons for the 2001-2002 OPS-
OPSEU EssentIal ServIces and CollectIve Agreement NegotIatIOns (the 2002
condItIons document) ThIS document contaInS the folloWIng defimtIOns of
essentIal and emergency serVIces
EssentIal servIces shall be determIned In accordance wIth sectIOn 30
of CECBA 1993
EmergencIes are those servIces specIfied In bargaInIng umt essentIal
servIce agreements and any other unforeseen CIrcumstances whIch call
for Immediate actIOn that falls wIth the defimtIOn of sectIOn 30 of
CECBA 1993
The tenns and condItIons of employment for employees provIdIng
essentIal and emergency serVIces are governed by artIcle C3a of the
condItIons document
All collectIve agreement prOVISIOns apply to essentIal and emergency
workers wIthout InterruptIOn, save only that AppendIx 9 and
AppendIx 18 shall not apply
6
WIth respect to Umon dues, the Umon can set dues (regular and
supplementary) dunng a strike or lockout for essentIal and emergency
employees who perform work, and the Employer shall remIt them,
except that the total deductIOn shall not be In excess of 31 375%
F or employees who are desIgnated and used for essentIal serVIces the
above terms and condItIons of employment apply
F or those employees who are used to perform emergency servIces as
provIded In the emergency servIces part of the essentIal servIces
agreements and as reqUIred by the Employer the above terms and
condItIons of employment apply After detennInIng that an employee
IS to be used to perform emergency serVIces work, the above terms
and condItIons of employment apply
The collectIve agreement referenced IS the 1999-2001 contract
III
The apphcatIOn of a collectIve agreement to emergency employees was
consIdered by thIS board In two cases arISIng out of the first OPSEU strike
In 1996 (1) OP SEU (Couszns) and Mlnzstry of Solzcltor General and
CorrectlOnal Servlces, decIsIOns dated July 23, 1996, GSB FIle No 822/96
(Roberts), (2) OPSEU (Burm,) andMlnzstry ofSolzcltor General and
CorrectlOnal Servlces, decIsIOns dated July 23, 1996, GSB FIle No 823/96
(Roberts) At that tnne, sectIOns 40(4) and 41(3) ofCECBA stated that a
collectIve agreement apphed to essentIal and emergency employees "used"
dunng a work stoppage, "unless the employer and trade umon agree
otherwIse" (These prOVISIOns have SInce been repealed.) In ('ouszns and
Burns the board was called upon to Interpret documents whIch dId provIde
otherwIse
The gnevor In Couszns was desIgnated as an emergency employee,
her "name appeared on a hst of personnel to be called In to replace any
7
essentIal employees who were away from work" (page 1) She claimed
reImbursement for dental expenses Incurred by famIly members on March 7
and 26 On March 20, she was scheduled to work on March 30 and 31 and
Apnll, 2, and 5 The umon contended the gnevor was entItled throughout
the strike to dental benefits, under the expIred collectIve agreement, because
she had been desIgnated to perform emergency servIces AccordIng to the
employer, her entItlement was hmIted to dental work done on days she
reported for duty VIce-Chair Roberts rejected both of these arguments as
unsupported by the wordIng of the apphcable condItIons document, dated
January 11, 1996
He rehed upon the thIrd paragraph In artIcle C 1 of the 1996 document whIch
IS IdentIcal to the fourth paragraph In artIcle C3a of the 2002 verSIOn quoted
above Mr Roberts wrote
ThIS wordIng dId not say that once an employee actually commenced
the perfonnance of emergency servIces work, he or she would be
covered by the collectIve agreement Instead, It stated that "the
collectIve agreement wIll apply" after "detennInIng that an employee
IS to be used to perform emergency serVIces work." ThlS made the
"key" to applzcatlOn of the collectlve agreement the date upon whlch
the employer actually "determzned" to use an employee zn th,S way
In my opznlOn, the date upon whlch the employer "determzned"
that the grzevor would be used to peiform emergency servlces work
was the date upon whIch she was scheduled to work dunng the strike,
1 e , March 20, 1996 Pnor to that date, there was too much
uncertaInty The gnevor was Just one among a number of employees
deemed quahfied to perform such work. She mIght never have been
called upon to work dunng the stnke Once the gnevor was scheduled
to work, however, all uncertaInty came to an end The employer had
"determIned" to use the gnevor to perform emergency servIces work
wItlun the meanIng of the "CondItIons" agreement From that date
untzl the completlOn of per:formance of the work, the prOV1SlOns of the
collectlve agreement -- zncludzng the dental bene.fit plan -- applzed to
the grzevor
8
ThIS means that when dental servIces were provIded to the
gnevor's husband, Robert, on March 26, 1996, the gnevor was
covered by the benefit plans Included In the collectIve agreement
When dental serVIces were provIded to her son, Aaron, on March 7,
1996, however, the gnevor was not covered. (pages 4 and 5, emphasIs
added)
In short, the condItIons document was Interpreted to mean that entItlement to
dental benefits began when an employee was scheduled to work and ended
when all scheduled work was fimshed.
The gnevor In Burns was a correctIOnal officer Officers at each
InstItutIOn were dIvIded Into two groups, wIth essentIal servIces beIng
provIded by one group for the first penod of two weeks, then by the other
group for the next two weeks, and so on Dunng any two-week penod when
a partIcular group of employees was not provIdIng essentIal servIces, they
could be called upon In an emergency The gnevor vIsIted hIS dentIst on the
second day of the strike, when he was aVailable to perform emergency
servIces but not reqUIred to provIde essentIal serVIces HIS entItlement to be
reImbursed for dental benefits was determIned by reference to the essentIal
servIces umbrella agreement for the correctIOnal servIces bargaInIng umt
(The decIsIOn makes no mentIOn of the condItIons document consIdered In
Cowans) The relevant prOVISIOns of the umbrella agreement stated.
6 All prOVISIOns of the collectIve agreement shall apply to bargaInIng
umt employees desIgnated to provIde emergency serVIces under tlus
agreement, or as agreed to by the partIes at the central table
21 (c) It IS understood that employees are only deemed to be essentIal
for the rotatIOnal penod dunng whIch they are reqUIred to work It IS
also understood that at all other tunes they are deemed to be
emergency servIce personnel
ApplYIng these sectIOns to the facts at before hIm, Mr Roberts wrote
9
EquatIng "desIgnated" under sectIOn 6 of the emergency serVIces
agreement WIth "deemed" under sectIOn 21 (c) of the umbrella
agreement would lead to the conclusIOn that the partIes Intended the
collectIve agreement to apply to all correctIOnal officers In the
bargaInIng umt throughout the entIre penod of the strike Throughout
thIS penod, correctIOnal officers were deemed under the umbrella
agreement to be eIther essentIal workers or emergency serVIces
personnel AccordIng to the submIssIOns of the umon, the collectIve
agreement would apply to them regardless of whIch they were deemed
to be It would not matter If a correctIOnal officer were ever called In
to perform emergency serVIces work It would not matter If the
correctIOnal officer spent all of Ius non-essentIal rotatIOn of the pIcket
hne To ascribe so far-reachIng an IntentIOn to the partIes--and In
partIcular, the employer--would be unreasonable
It seems to me that the more reasonable InterpretatIOn of
"desIgnated" under sectIOn 6 of the emergency serVIces agreement
would be to equate It to "scheduled" or "called In" by the employer to
provIde emergency servIce Scheduhng or callIng In an employee for
thIS purpose would seem to be an appropnate pOInt at whIch to tngger
apphcatIOn of the collectIve agreement to an otherwIse-strikIng
employee It IS then that the nghts and responsibIhtIes of the employer
and employee under the emergency servIces agreement crystalhze
The employer expects to receIve emergency serVIces at a specIfic tIme
from a specIfic employee The employee IS reqUIred to provIde them
In return, the employee reasonably expects to receIve the benefit of
the collectIve agreement
In the present case, the gnevor Incurred Ius dental expense on
the day after the commencement of the strike At that tlme, he was
deemed to be emergency serVlces personnel under the umbrella
agreement but had not been scheduled or called zn by the employer to
per:form emergency serVlces Accordzngly, the collectlve agreement
dld not apply to the grzevor at the tllne of hlS dental expense, and he
cannot claim reImbursement under the dental benefit plan of the
agreement (pages 3 and 4, emphasIs)
In other words, the gnevor's claim for reImbursement was demed because
Ius dental expenses had been Incurred before he had been called In or
scheduled to work as an emergency employee
10
IV
ThIS sectIOn of my award addresses the apphcatIOn of the 1999-2001
collectIve agreement to emergency employees, the entItlement of essentIal
employees IS consIdered In the next sectIOn As the same paragraph deahng
wIth emergency employees appears In both the 1996 document and the one
for 2002, I begIn wIth the meanIng of tlus paragraph, vIewed In the context
of the earher document, and then consIder the ImphcatIOns of changes made
elsewhere In the later document The paragraph IS repeated here for ease of
reference
F or those employees who are used to perform emergency servIces as
provIded In the emergency servIces part of the essentIal servIces
agreements and as reqUIred by the Employer the above terms and
condItIons of employment apply After detennInIng that an employee
IS to be used to perform emergency serVIces work, the above terms
and condItIons of employment apply
Counsel on each sIde argued the two sentences In tlus paragraph deal
wIth mutually exclusIve subjects AccordIng to umon counsel, the second
sentence IS about emergency workers IdentIfied through a fonnal desIgnatIOn
process and the first sentence about those selected In some other way
Employer counsel contends the first sentence deals wIth servIces specIfically
IdentIfied In an emergency servIces agreement and the second wIth other
emergency servIces As neIther sentence makes any mentIOn of a partIcular
type of servIce or a partIcular mode of selectIOn, I conclude both of these
InterpretatIOns are dubIOus
Both are also at odds wIth the ruhng In Couszns VIce-Chair Roberts
drew no dIstInctIOn between types of emergency serVIces or methods of
selectIng emergency workers, merely notIng the gnevor's name was on a hst
11
of people to be used as replacements He read the second sentence as
ImpOSIng a temporal hmItatIOn on the entItlement of emergency employees
under a collectIve agreement In other words, he treated both sentences as
governIng all emergency employees, wIth the first saYIng the collectIve
agreement apphed to them, and the second modIfYIng the first by addIng a
tune hmIt In my VIew, tlus IS the most reasonable InterpretatIOn of how the
1996 document dealt wIth emergency servIces
Does the Cowans decIsIOn offer any gUIdance about the proper
treatment of emergency workers dunng the 2002 strike? ArtIcle C3a of the
2002 document omIts one proVIsIOn found In the 1996 verSIOn and contaInS
two others not found there All relevant parts of the later document are
quoted In the second sectIOn of thIS award The correspondIng paragraphs
from the ear her one state
F or employees who are on strike, the collectIve agreement apphes
F or employees who are desIgnated and used for essentIal serVIces the
above terms and condItIons of employment apply
F or those employees who are used to perfonn emergency servIces as
provIded In the emergency servIces part of the essentIal servIces
agreements and as reqUIred by the Employer the above terms and
condItIons of employment apply After determInIng that an employee
IS to be used to perform emergency serVIces work, the above terms
and condItIons of employment apply
Counsel for the umon notes the first paragraph, about "employees
who are on strike", IS omItted from the 2002 condItIons document The
sIgmficance of the omISSIOn depends upon what thIS clause meant In 1996
The overall stnlcture of the earher document IS not hard to dIscern ArtIcle
Cl has three paragraphs, each deahng wIth a dIfferent category of
employees the first addresses those on stnke, who have not been desIgnated
12
to provIde essentIal or emergency servIces, the second concerns essentIal
workers and the thIrd emergency workers The first paragraph makes the
ObVIOUS pOInt that the collectIve agreement does not apply to employees who
are not desIgnated to provIde essentIal or emergency servIces As tlus
paragraph IS not about essentIal or emergency workers, ItS omIssIOn from the
2002 document has no Impact on how the collectIve agreement apphes to
them
The first two paragraphs of artIcle C3a of the 2002 document have no
counterpart In the one for 1996 For ease of reference, these prOVISIOns are
repeated here
All collectIve agreement prOVISIOns apply to essentIal and emergency
workers wlthout znterruptlOn, save only that AppendIx 9 and
AppendIx 18 shall not apply
WIth respect to Umon dues, the Umon can set dues (regular and
supplementary) dunng a strike or lockout for essentIal and emergency
employees who per:form work, and the Employer shall remIt them,
except that the total deductIOn shall not be In excess of 31 375%
(emphasIs added)
EmphaSIZIng the words "who perfonn work" In the second paragraph,
umon counsel notes there IS no analogous language elsewhere In artIcle C3a.
In my VIew, thIS observatIOn does not assIst In constnllng the remaInIng
paragraphs The second paragraph allows the umon to Impose a levy on
essentIal and emergency workers, the only employees who receIve wages
from the employer dunng a strike, In order to raise money for dIstnbutIOn to
stnkers who have forgone all such wage payments Once the decIsIOn to
have such a levy has been made, lOgIC dIctates that It apply only to those
"who perform work." Even If the document was not exphcIt on tlus pOInt,
one would Infer such a levy apphes exclusIvely to workIng employees For
13
thIS reason, I conclude the InSertIOn of the phrase "who perform work" In the
second paragraph has no real sIgmficance and does not suggest the partIes
Intended paragraphs lackIng tlus phrase to Include non-workIng employees
Umon counsel also rehes upon the words "wIthout InterruptIOn" In the
first paragraph of artIcle C3a. These words first appeared In an OLRB order,
dated January 12, 1999, Issued because the partIes where unable to agree on
how the collectIve expInng In 1998 would apply dunng a work stoppage, If
one occurred dunng negotIatIOns for ItS renewal (By thIS tIme, CECBA no
longer dealt wIth the apphcatIOn of a collectIve agreement dunng a stnke or
lockout) The OLRB order stated that "all collectIve agreement prOVISIOns
apply to essentIal workers wIthout InternlptIOn", save for AppendIx 9 whIch
was later determIned not to apply In a later decIsIOn, dated January 27,
1999, the OLRB IndIcated the term "essentIal" had been used to Include
"emergency" (paragraphs 6 and 10) The partIes subsequently executed a
condItIons document, dated February 4, 1999, contaInIng terms whIch are
IdentIcal, for present purposes, to artIcle C3a of the 2002 document (The
only dIfference IS that the later document mentIOns AppendIx 18 as well as
AppendIx 9 )
The most ObVIOUS purpose of the first paragraph of artIcle C3a IS to
IndIcate that the entIre collectIve agreement, wIth the sole exceptIOn of two
appendIces, apphes to employees provIdIng essentIal or emergency servIces
The accomphshment of tlus purpose dId not reqUIre InsertIng the words
"wIthout InterruptIOn" Counsel contends these two words were Inserted to
ensure an employee desIgnated to provIde essentIal or emergency serVIces
was covered by the collectIve agreement throughout a work stoppage
AccordIng to tlus argument, the added words were meant to reverse the
14
nllIng In Cowans that a collectIve agreement dId not apply to an emergency
employee before work was scheduled or after It was completed
The ObVIOUS counter argument IS that the paragraph about emergency
workers, upon whIch the Couszns decIsIOn was based, was carrIed over In ItS
entIrety from 1996 to 2002 It IS now the fourth paragraph of artIcle C3a.
VIce-Chair Roberts construed the second sentence In tlus paragraph as
servIng the sole purpose of unpOSIng a temporallunItatIOn on the first,
whIch says the collectIve agreement apphes to emergency employees If the
phrase "wIthout InterruptIOn" In the opemng paragraph of artIcle C3a IS read
to say they are covered by the collectIve agreement for the duratIOn of a
work stoppage, the first paragraph dIrectly contradIcts the fourth as
Interpreted In Cowans Such a contradIctIOn would produce an ambIgUIty
about whether the temporallunItatIOn from 1996 survIved In 2002 The
clearest way to over-nde the nllIng In Cowans would have been to delete or
modIfy the second sentence In the paragraph about emergency workers ThIS
was not done
Counsel for the employer contends emergency employees are entItled
to the benefit of the collectIve agreement only when workIng because they
are on strike the rest of the tune ThIS argument IS based upon s 41 (2) of
CECBA repeated below for ease of reference
Employees who have been not~fied that the employer IS entItled to use
them under subsectIOn (1) and wIshes to do so may not strike wlule
the employer IS so entItled and so wIshes (emphasIs added)
Counsel reads thIS prohIbItIon agaInst emergency employees gOIng on strike
as applYIng only when they are perfonnIng essentIal servIces The same
constructIOn was adopted by the OLRB In OPSEU and Crown zn Rlght of
OntarlO [1995] O.L.R.B 735 at paragraph 22 I note thIS InterpretatIOn pays
15
no heed to the words "who have been notIfied" ThIS phrase makes the nght
to stnke depend, not on what employees are dOIng, but rather on what
notIficatIOn they have receIved. I need not dwell upon the proper
InterpretatIOn of tlus sectIOn, because CECBA no longer governs the
apphcatIOn of a collectIve agreement dunng a strike, leavIng thIS matter to
be detennIned by the partIes TheIr detennInatIOn IS embodIed In the 2002
condItIons document and my task IS to Interpret artIcle C3a of that
document
The foregoIng analysIs leads me to conclude Couszns contInues to
embody the rules detennInIng when emergency employees enJoy the benefit
of the collectIve agreement The decIsIOn In that case set out the rules
applYIng In 1996 The same nlles contInued to apply In 2002, because the
current condItIons document IS ambIguous as to whether they have been
changed.
V
I turn now to consIder how the collectIve agreement apphes to employees
desIgnated to perfonn essentIal serVIces
Does the Burns decIsIOn offer any gUIdance on tlus subJect? The
gnevor In that case rotated between beIng aVailable to work as an emergency
employee In one two-week penod and workIng as an essentIal employee In
the next He belonged to the group of employees slated to begIn perfonnIng
essentIal servIces In the thIrd week of the strike When he went to the dentIst
on the second day of the work stoppage, he was slated to provIde essentIal
servIces In less than two weeks The effect of the decIsIOn In Burns was to
deny hun reImbursement for a dental expense Incurred In the Interval
between the scheduhng and performance of essentIal work, even though he
16
would have been reImbursed for a sImIlar expense Incurred between the
scheduhng and performance of emergency work. VIce-Chair Roberts
analysIs In Burns acknowledges the gnevor's role as an essentIal employee,
but makes no mentIOn of the dental appoIntment occurnng wlule he was
scheduled to do essentIal work As well as gloSSIng over thIS fact, the Burns
decIsIOn does not cIte any proVISIOn, from eIther the condItIons document or
the correctIOns umbrella agreement, specIfYIng how the collectIve agreement
apphes to employees performIng essentIal servIces The decIsIOn IS based
exclusIvely upon provIsIOns In the umbrella agreement dealIng wIth
emergency employees For these reasons, I conclude the ruhng In Burns
provIdes no authontatIve gUIdance as to the proper treatment of essentIal
employees, even In the context of the 1996 stnke
The treatment of essentIal employees In 2002 IS governed by the first
and thIrd paragraphs of artIcle C3a. The thIrd paragraph, deahng exclusIvely
wIth essentIal workers, contaInS wordIng sIgmficantly dIfferent than the
fourth paragraph, dealIng exclusIvely wIth emergency workers The first,
tlurd and fourth paragraphs are repeated here for ease of reference
All collectIve agreement prOVISIOns apply to essentIal and emergency
workers wIthout InterruptIOn, save only that AppendIx 9 and
AppendIx 18 shall not apply
F or employees who are desIgnated and used for essentIal serVIces the
above terms and condItIons or employment apply
F or those employees who are used to perform emergency servIces as
provIded In the emergency servIces part of the essentIal servIces
agreements and as reqUIred by the Employer the above terms and
condItIons of employment apply After determlnzng that an employee
IS to be used to perform emergency serVIces work, the above terms
and condItIons of employment apply (emphasIs added)
17
The word "after" In the fourth paragraph has no analogue In the
second. ThIS IS the very word that led VIce-Chair Roberts In Cowans to
conclude there was a temporallunItatIOn on the apphcatIOn of the collectIve
agreement to emergency workers He read "detennInIng" to mean
scheduhng and held that the collectIve agreement apphed only after an
employee had been scheduled to work. The omISSIOn of "after" In the tlurd
paragraph suggests essentIal workers are not subJect to the same temporal
hmItatIOn as those performIng emergency serVIces ThIS InterpretatIOn IS
reInforced by the words "wIthout InterruptIOn" In the openIng paragraph
Counsel for the umon contended the word "and" In the second
paragraph, about essentIal employees, should be treated as dIsJunctIve rather
than conJunctIve I reJect thIS suggestIOn that "and" means "or" The second
paragraph creates two condItIons for coverage under the collectIve
agreement To have the benefit of the agreement, an employee must be
desIgnated to do essentIal work and actually do some The collectIve
agreement has no apphcatIOn to an employee who IS desIgnated to perfonn
essentIal serVIces but who does no such work dunng a work stoppage
F or an employee who IS desIgnated to provIde essentIal servIces and
does so, when does he or she begIn to receIve the protectIOn of the collectIve
agreement and when does that protectIOn cease? The absence of any
temporal hmItatIOn In the thIrd paragraph of artIcle C3a, together wIth the
phrase "wIthout InterruptIOn" In the first, IndIcate that such an employee IS
covered by the collectIve agreement from the first day of the work stoppage
to the last
18
VI
My conclusIOns about artIcle C3a of the 2002 condItIons can be bnefly
summarIzed.
1 An emergency worker was covered by the collectIve agreement
In the Interval between beIng scheduled to work and completIng
all scheduled work The collectIve agreement dId not apply to
such an employee before beIng scheduled to work or after all
scheduled work had been completed.
2 The collectIve agreement has no apphcatIOn to an employee
who was desIgnated to provIde essentIal serVIces but performed
no such work dunng the strike
3 An employee who was desIgnated to perform essentIal serVIces,
and who dId so, was covered by the collectIve agreement for the
entIre duratIOn of the stnke
The collectIve agreement apphed dIfferently to emergency workers than to
essentIal workers, even though the fonner sometImes were scheduled for
duty In much the same way as were the latter ThIS dIfferentIal treatment IS a
product of the condItIons document whIch recogmzes two categones of
employees and uses very dIfferent language to descnbe the apphcatIOn of the
collectIve agreement to one than to the other
RemaInIng to be determIned IS what these general conclusIOns about
collectIve agreement coverage Imply about entItlement to hohday
com pensatIon
Issued at Toronto tlus 4th day of December, 2002
;iZ'
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RIchard Brown
VIce-Chair