HomeMy WebLinkAbout2003-1631.Miller.05-03-31 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
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Suite 600 Bureau 600 Ontario
180 Dundas Sl. West 180 rue Dundas Ouest
Toronto Ontario M5G 1Z8 Toronto (Ontario) M5G 1Z8
Tel. (416) 326-1388 Tel. (416) 326-1388
Fax (416) 326-1396 Telec. (416) 326-1396
GSB# 2003-1631
UNION# OLB335/03
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano LIqUor Boards Employees' Umon
(Miller) Union
- and -
The Crown In RIght of Ontano
(LIqUor Control Board of Ontano) Employer
BEFORE Reva DevIns Vice-Chair
FOR THE UNION Graham WillIamson
Koskie Minsky LLP
Barnsters and SOlICItorS
FOR THE EMPLOYER Gordon FItzgerald
Counsel
LIqUor Control Board of Ontano
HEARING February 7 2005
2
Award
The gnevor Ms Jamce Miller IS a casual employee at LCBO Store 340 In Area J She applIed
for a permanent vacancy In her Area and now gneves her non-selectIOn. The partIes agree that
she had qualIficatIOns and abIlItIes relatIvely equal to the persons to whom the jobs were
awarded and that she was the semor employeeI
The Employer acknowledged that the Job PostIng descnbed a vacancy In Area J and that It
determIned the specIfic locatIOn of the vacanCIes after the posItIOns were posted. Once the
Employer IdentIfied the exact locatIOn of the vacanCIes, at Store 353 and 390 It selected the
successful candIdates from those applIcants who were wIthIn the geographIc postIng area for
those stores SInce the vacanCIes were not WIthIn the gnevor's geographIc postIng area, she was
not consIdered for selectIOn.
The Umon acknowledges that had the postIng specIfically advertIsed a vacancy at Store 353 or
Store 390 Ms Miller would not be elIgIble for consIderatIOn. Nonetheless, In the Umon's
submIssIOn, the Employer IS bound by the partIculars It provIded In the Job PostIng and IS not
entItled to subsequently rely on a more restnctIve desIgnatIOn.
In thIS case, SInce the Employer advertIsed a vacancy In Area J that posItIOn should be avaIlable
to all casual employees who worked at stores In that Area. As the more semor applIcant from
Area J the gnevor should have been selected In advance of the Incumbents
The Employer submIts that ArtIcle 31 4 of the collectIve agreement lImIts casual employees to
vacanCIes In theIr' geographIc area' The boundanes of the geographIc areas were further defined
by the partIes and are expressed as the GeographIc PostIng Area. It IS the Employer's posItIOn
that, regardless of what IS set out In the postIng document, casual employees are only elIgIble to
apply for vacanCIes In theIr geographIc area. In thIS case, neIther vacancy occurred at a store
1 The parties advised that the incumbents had been notified of this Arbitration, however, neither incumbent attended
nor did they indicate to either the Employer or the Union that they intended to attend.
3
wIthIn the gnevor's GeographIc PostIng Area and the Employer was therefore reqUIred to
proceed on the basIs that she was not elIgIble for consIderatIOn at these locatIOns
Agreed Statement of Facts
The partIes submItted the folloWIng agreed statement of facts
1 The Employer created ajob postIng for a full tIme LIquor Store Clerk Grade 3 The
postIng date was Apnl 30 2003 and the cloSIng date was May 14 2003 The postIng
IndIcates that all bargaInIng umt employees In "Area J" may apply and that the
locatIOn of the posted posItIOn IS In "Area J" A copy of the postIng IS attached at Tab
1
2 The PartIes have agreed to a senes of GeographIc PostIng Areas These are the
"geographIc areas" referred to In ArtIcle 21 4(a)(l) and ArtIcle 31 4 of the collectIve
agreement, GeographIc PostIng Area J Includes the folloWIng Stores 145 209 226
248 265 311340 346 353 390 404 453 523 529 536 590 612,618 623 693
and 783 Attached at Tab 2 IS a copy of the GeographIc PostIng Areas as agreed to by
the PartIes
3 Ms Jamce Miller (the "Gnevor") IS a casual employee She submItted an applIcatIOn
for consIderatIOn In respect of the above-noted postIng.
4 On or about June 13 2003 the Employer produced an announcement In respect of the
postIng. A copy of the announcement IS attached at Tab 3 The Gnevor was not
consIdered for or awarded the postIng.
5 The Umon, on ItS own behalf, and on behalf of the Gnevor filed a Gnevance In
respect of the postIng. A copy of the Gnevance IS attached at Tab 4 In the
Gnevance the Umon alleges that the Employer Improperly faIled to consIder the
Gnevor for consIderatIOn In the postIng.
6 The partIes agree that If the Gnevor was elIgIble to apply for the posItIOn set out In
the postIng (whIch IS the Umon's posItIOn, but whIch IS demed by the Employer) the
Gnevor had qualIficatIOns and abIlItIes relatIvely equal to the persons to whom the
job postIng was awarded, and was the semor employee
7 The PartIes agree that, pursuant to theIr Agreement In respect of the GeographIc
PostIng Areas, the Gnevor's store, Store 340 falls wIthIn Area J By way of
background, letters are used to desIgnate some geographIc areas wIth large numbers
of stores It IS the Employer's posItIOn, whIch IS not agreed to by the Umon, that Store
340 IS only part of Area J to the extent that employees In Store 340 are elIgIble for
vacanCIes In Stores 226 and 453
8 When the Employer sent out the announcement at Tab 3 IndIcatIng the fillIng of the
postIng, It provIded the locatIOn of the posItIOn as beIng at Stores 353 and 390
Without prejUdICe to any further or any other matter between the PartIes, the Umon
4
acknowledges that had the postIng been advertIsed for a vacancy In Store 353 and/or
390 the Gnevor would not be elIgIble for consIderatIOn. ThIS IS because, wIth
reference to Tab 2, In order to determIne whIch stores an employee IS elIgIble to be
consIdered for a postIng, the employee finds theIr current store In the left hand
column of the GP A lIstIngs and then references the Geo Posts column to find elIgIble
stores
9 It IS the Umon's posItIOn, whIch IS not agreed to by the Employer that In thIS case,
the Employer decIded that the postIng would be avaIlable to all employees In Area J
and IndIcated that the vacancy eXIsted In Area J and that as the Employer dId not
specIfy a store locatIOn for the vacancy It cannot rely upon the lImItatIOn In the
GeographIc PostIng Areas agreed to by the PartIes
10 It IS the Employer's posItIOn, whIch IS not agreed to by the Umon, that regardless of
what the postIng Itself may state, employees from Store 340 are only ever elIgIble to
apply for vacanCIes In Stores 139 224 226 340 453 562, and 596 HavIng decIded
that vacanCIes eXIsted at Stores 353 and 390 the Employer was entItled to determIne
that the Gnevor was not elIgIble for consIderatIOn gIven that her store IS Store 390
11 The PartIes agree that, pnor to the announcement set out at Tab 3 the employees In
the bargaInIng umt were not advIsed of whIch stores the postIng (attached at Tab 1)
was for
Additional evidence presented by the employer
In addItIOn to the Agreed Statement of Fact, eVIdence was provIded by Paul ManCInI, the DIstnct
Manager at the tIme of the postIng and Yolande Watson, the Human Resource Manager As
DIstnct Manager Mr ManCInI was responsible for the operatIOns, human resources and budget
of the stores In DIstnct 18 Ms Watson was responsIble for the postIng process Both of the
Employer's wItnesses testIfied to the operatIOnal structure of the LCBO and the CIrcumstances
surroundIng the postIng In Issue TheIr eVIdence was by and large not dIsputed by the Umon.
Mr ManCInI'S DIstnct IS In Central RegIOn and Includes Stores 353 and 390 the sItes eventually
chosen for the posted vacancy For admInIstratIve convemence, desIgnated areas that contaIn a
large number of stores are referred to by a sIngle letter Area J A or G The Employer relIes on
the applIcable letter desIgnatIOn as a form of short hand to aVOId lIstIng each of the Included
stores IndIVIdually
In most letter desIgnated areas, casual employees are elIgIble to apply for permanent posItIOns at
any other store In theIr own letter area. That IS not the case In Area J where casual employees do
not enjoy full recIprocIty WIthIn theIr letter desIgnated area. Store 340 the store where the
5
gnevor IS employed, IS one of the anomalIes In Area J The GeographIc PostIng Area for Store
340 IS confined to Stores 139 224 226 340 453 562 and 596 Of those stores, only Stores 226
340 and 453 are In Area J Employees at Store 340 are therefore only elIgIble for a few stores In
Area J whereas the maJonty of stores In Area J are not wIthIn theIr GeographIc PostIng Area.
The partIes have an ongOIng agreement2 that reqUIres the postIng of a full tIme posItIOn where
casual employees work In excess of a specIfied number of hours In a calendar year DesIgnates
of the Employer and Umon attend an annual meetIng to determIne whether the use of casual
employees has generated the creatIOn of a permanent posItIOn (the PVR meetIng) Once It IS
determIned that a vacancy eXIsts, the posItIOn need not be filled at the locatIOn nor by the
IndIVIdual that generated the vacancy
Pursuant to the 2003 PVR meetIng, a vacancy was declared In DIstnct 18 Mr ManCInI realIsed
ImmedIately that Store 783 the locatIOn that generated the posItIOn, could not support another
full tIme employee ThIS sIte was very small and was already sufficIently staffed. Another one of
hIS stores, Store 390 was scheduled to double ItS retaIl floor space and based on hIstoncal data
Mr ManCInI antIcIpated that the volume of sales at thIS locatIOn would Increase by 20-30% On
thIS basIs Mr ManCInI ultImately concluded that the best operatIOnal use of another full tIme
posItIOn would be at that locatIOn. He dId not decIde where the vacancy would be filled untIl
after the Job was posted
Mr ManCInI subsequently IdentIfied a further vacancy at Store 353 The first Incumbent, selected
to fill the vacancy at Store 390 had been workIng as a casual employee at Store 353 and hIS
departure, along wIth the absence of a full tIme employee on maternIty leave, persuaded Mr
ManCInI that an addItIOnal vacancy should be filled at a second store ThIS vacancy was also
filled from the applIcants to the Apnl 30 2003 PostIng.
Once the locatIOns were IdentIfied, the successful candIdates were selected havIng regard to who
was the most semor qualIfied, elIgIble casual employee elIgIbIlIty was determIned on the basIs
of the agreed to GeographIc PostIng Areas Both of the Incumbents applIed as casual employees
and were employed at Stores that Included Store 390 and 353 wIthIn theIr GeographIc PostIng
2 Set out in a letter of understanding.
6
Area. The IdentIfied vacanCIes were not sItuated at stores that were wIthIn Ms Miller's
GeographIc PostIng Area and she was therefore not consIdered. In makIng the selectIOns, Mr
ManCInI testIfied that he was not motIvated by favountIsm to the two Incumbents nor ammus
towards the gnevor Mr ManCInI had not met Ms Miller and was not aware of her
qualIficatIOns Nor was he aware that the Incumbents had applIed for the vacancy untIl after the
cloSIng date for the PostIng.
Ms Watson, the human resource manager responsIble for the relevant Job PostIng document,
confirmed that she was unaware of the preCIse locatIOn of the vacancy untIl after the postIng
document was prepared. She knew that the vacancy would not be filled at the locatIOn that
generated the posItIOn at the PVR meetIng but she dId not know where the new posItIOn would
be sItuated. Therefore she chose to descnbe the locatIOn of the vacancy In the Job PostIng In the
broadest possIble terms to ensure that everyone who could be elIgIble for the posItIOn was aware
of the postIng and could apply If they were Interested.
On cross eXamInatIOn, Ms Watson agreed that the LCBO can and has posted for vacanCIes at
specIfic store sItes, although she also testIfied that Central RegIOn has not. In any event, In thIS
case, she was unaware of the ultImate locatIOn for the vacancy and so she Instructed the clerk to
post the job In Area J to aVOId unduly restnctIng Interested casual employees from applYIng for a
posItIOn for whIch they mIght ultImately be elIgIble
Collective Agreement
The relevant provIsIOns of the CollectIve Agreement are as follows
Article 21
Assignments and Job Postings
21 4 (a )(i) If a new job classIficatIOn WIthIn the bargaInIng umt IS created, or a
permanent vacancy occurs In an eXIstIng job classIficatIOn, before InVItIng
applIcatIOns from persons not employed by the Employer or employees
who are outsIde of the bargaInIng umt, the Employer wIll post wIthIn the
geographIc area as specIfied, notIce of such new job or vacancy for a
penod often (10) workIng days dunng whIch employees wIthIn such area
may apply The notIce shall stIpulate qualIficatIOns, classIficatIOn, salary
range, department and locatIOn concerned.
Article 31
7
Casuals
The provIsIOns of thIS CollectIve Agreement shall apply to casuals except wIth respect to
the folloWIng modIficatIOns and exceptIOns lIsted In ArtIcle 31 3
31 3 The applIcatIOn of ArtIcle 21IS lImIted by the provIsIOns of ArtIcle
314 below
31 4 (a) Casuals shall have the nght to apply for certaIn permanent part- tIme
posItIOns In accordance wIth the provIsIOns of ArtIcle 21 AssIgnments &
Job PostIngs They shall, however only be elIgIble to apply for vacanCIes
WIthIn theIr geographIc areas If there IS no permanent part-tIme employees
promoted In accordance wIth ArtIcle 21 5(a)
(b) The Employer agrees to gIve consIderatIOn to the qualIficatIOns and abIlIty
of casuals for permanent full-tIme vacanCIes at the entry level In theIr
geographIc area, provIded that no permanent part-tIme employees have
applIed Where qualIficatIOn and abIlIty are relatIvely equal, semonty shall
be the determInIng factor
Submissions
The Umon submIts that the Employer must be reqUIred to stnctly adhere to the terms of the Job
PostIng document to ensure fairness and transparency In the selectIOn process In It'S submIssIOn,
the Employer was free to desIgnate a vacancy at a partIcular store and, had they done so then the
lImItatIOns contaIned In the GeographIc PostIng Area would have properly defined elIgIbIlIty In
thIS case, however the Employer desIgnated the locatIOn of the vacancy In the Job PostIng as
Area J and the gnevor who IS elIgIble for Area J posItIOns, IS entItled to be consIdered for the
vacancy as It was descnbed In the Job PostIng. In the Umon's submIssIOn, the Employer erred by
dIsregardIng the PostIng Document and retroactIvely applYIng the lImIts set out In the
GeographIc PostIng Area to exclude the gnevor
The Umon maIntaInS that the GeographIc PostIng Area only applIes when the Employer
IdentIfies the store locatIOn In the postIng Itself and that where they faIl to do so they are bound
by the locatIOn IdentIfied In the Job PostIng. In a case such as thIS, where the Employer elects to
declare a vacancy In a general area, applIcants are entItled to rely on the terms set out In the
postIng and the Employer cannot subsequently lImIt elIgibIlIty by ImpOSIng narrower terms It
would be Inherently arbItrary and unreasonable to allow the Employer to mampulate the process
In thIS manner
8
Upon heanng the eVIdence ofMr ManCInI wIth regard to the second vacancy the Umon also
asserted that that selectIOn was Improper as It was filled wIthout the benefit of an Independent
Job PostIng. The second posItIOn was created well after the postIng had closed and should
therefore be re-run.
In support, of ItS posItIOn the Umon cItes Re Fletcher Challenge Canada Ltd and
Communications Energy andPaper)1,orkers Union, Local1l23 (1997),62 L AC (4th) 62
(Taylor) Re Northern Electric Co and United Automobile Workers, Local 27 (1972) 1 L.A C
(2d) 51 (Palmer) Re Mount Sinai Hospital and Ontario Nursing Association (1991), 13 LAC
(4th) 230 (HaeflIng) Re Co-Operative Regionale de Nipissing Sudbury Ltd and R. WD S. U
(1998), 77 L AC (4th) 328 (Solomentenko) and CanadIan Labour ArbItratIOn, ThIrd Ed. para.
5 2524 (Brown and Beatty)
In the Employer's VIew a vacancy In the casual employee's geographIc postIng area IS a pre-
condItIOn to consIderatIOn of theIr applIcatIOn for a full tIme posItIOn regardless of the content of
the Job PostIng. In thIS case the gnevor's GeographIc PostIng Area was lImIted to some but not
all of the stores In Area J Once the final determInatIOn was made IdentIfYIng the specIfic stores
where the vacanCIes would be filled, the Employer was oblIged by the terms of ArtIcle 31 4 to
select applIcants who were elIgIble for those sItes, to do otherwIse would be to Ignore the clear
provIsIOns of the collectIve agreement.
The Employer suggested that they are free to set out the locatIOn of a vacancy In the broad terms
employed In thIS case In any event, If they are not, the Employer's only error In thIS Instance
was theIr faIlure to set out a more preCIse locatIOn for the vacancy when It was posted. In theIr
submIssIOn, even If the Job PostIng should have provIded a more specIfic locatIOn, the gnevor
cannot be awarded a posItIOn for whIch she IS not elIgIble under the express terms of the
collectIve agreement.
In support of ItS posItIOn, the Employer cItes Re Ontario Hydro and Canadian Union of Public
Employees Local 1000 (1987),30 L AC (3d) 331 (Brent) Re Marks and The Crown in Right
of Ontario (MinistlY of Natural Resources (1981),30 L AC (2d) 61 (Weathenll) Re Union Gas
Ltd and Energy and Chemical Workers Union, Local 764(1988), 1 LAC (4th) 254 (Palmer)
Re Hershey Canada Inc and Retail, Wholesale & Department Store Union. Us. WA. Local
9
461 (1995) 51 LAC (4th) 299 (Kates) Re International Nickel Co of Canada and United
Steehwrkers (1974),6 L AC (2d)104 (Rayner) and Re St. John sTraining Schoolfor Boys and
Ontario Public Service Employees Union, Local 361 (1999), 91 LAC (4th) 76 (Knopf:)
Analysis
Under the terms of the current collectIve agreement, casual employees have lImIted nghts to
apply for permanent posItIOns ArtIcle 31 4 restncts the scope of that entItlement and confines
casual employees to vacanCIes WIthIn theIr 'geographIc area' The partIes have delIneated the
specIfic lImIts of an IndIVIdual applIcants' 'geographIc area' and set them out In detaIled
GeographIc PostIng Areas whIch they have defined by reference to IndIVIdual stores The
Employer has ItS own letter desIgnated areas that by and large mIrror the GeographIc PostIng
Areas but whIch are not a perfect match.
The Issue that anses In thIS case IS a consequence of the lack of symmetry between the defined
GeographIc PostIng Areas and the language employed to descnbe the locatIOn of the vacancy
when the Employer's descnptIOn does not correspond to a locatIOn In the defined GeographIc
PostIng Areas, what 'locatIOn' defines elIgIbIlIty? The Umon submIts that an applIcant's
elIgIbIlIty IS governed by the terms set out In the Job PostIng document, whereas the Employer
maIntaInS that the selectIOn process, for casual employees, IS first and foremost determIned by
reference to ArtIcle 31 4
The facts In thIS case are not In dIspute The Employer advertIsed a vacancy wIthIn a broad
geographIc regIOn, IdentIfied as Area J wIthout further IdentIfYIng the store at whIch the vacancy
would be filled. SInce the defined boundanes of the GeographIc PostIng Areas are store specIfic,
potentIal applIcants who revIewed the Job PostIng would not have known whether the vacancy
was In theIr GeographIc PostIng Area. The Gnevor applIed for the vacancy and was elIgIble for
some stores wIthIn Area J the posted locatIOn of the vacancy
After the vacancy was posted, the Employer determIned the preCIse locatIOn where the posItIOns
would be filled. Stores 353 and 390 the ultImate sIte of the vacancIes, are not WIthIn the
gnevor's defined GeographIc PostIng Area and she was consequently not consIdered for the
vacanCIes It was conceded by the Umon that If the Employer had IdentIfied eIther of these stores
In the Job PostIng, the gnevor would not have been elIgIble for eIther vacancy The Employer
10
acknowledged that the gnevor possessed qualIficatIOn and abIlIty relatIvely equal to the
Incumbents and that she was the semor candIdate On the basIs of these agreed facts, the partIes
agree that the gnevor would be entItled to the vacancy If she IS elIgIble for consIderatIOn.
The Umon maIntaInS that the Employer elected to descnbe the locatIOn of the vacancy In very
general terms and that It InvIted applIcatIOns on that basIs The Umon suggested that the
Employer was free to desIgnate the locatIOn of the vacancy as they dId, however It was then
restncted to the terms It set In the Job PostIng. It was the Umon's posItIOn that the GeographIc
PostIng Areas only applIed when a specIfic store was IdentIfied In the Job PostIng Where the
Employer does not specIfy a store locatIOn In the postIng document, It cannot subsequently rely
on the lImItatIOns contaIned In the GeographIc PostIng Areas I was urged to maIntaIn the
transparency and preserve the Integnty of the selectIOn process by lImItIng the Employer In thIS
way
Although I have some sympathy for the Umon' s posItIOn, I do not thInk that the collectIve
agreement can be Interpreted In the manner that they contend. ArtIcle 21 4 provIdes that certaIn
detaIls of the vacancy must be Included In the notIce provIded to prospectIve applIcants IncludIng
"qualIficatIOns, classIficatIOn, salary range, department and locatIOn" Pursuant to ArtIcle 31 3
whIch governs casual employees, the applIcatIOn of ArtIcle 21 IS expressly lImIted by ArtIcle
31 4 ArtIcle 31 4 goes on to state that casual employees are eligible to apply for permanent
vacancies yt,ithin their geographic area and that the Employer wIll consIder the "qualifications
and ability of casuals for permanent full-time vacancies at the entry level in their geographic
area, provIded that no permanent part-tIme employees have applIed. Where qualIficatIOn and
abIlIty are relatIvely equal, semonty shall be the determInIng factor "(emphasIs added)
As acknowledged by the partIes, the collectIve agreement provIdes lImIted nghts to casual
employees ArtIcle 31 4 sets out the condItIOns that apply when casual employees are seekIng a
permanent posItIOn. A number of restnctIOns are enumerated, however chIef among them IS the
reqUIrement that the vacancy be In the applIcant's geographIc area. UltImately the partIes have
determIned that for casual employees, qualIficatIOn, abIlIty and semonty IS subordInate to
geographIc locatIOn. In my VIew thIS ArtIcle clearly establIshes that a casual employee's
elIgIbIlIty for a full tIme posItIOn IS contIngent on a vacancy anSIng In geographIc proxImIty to
11
that employee's eXIstIng posItIOn. There are no exceptIOns, qualIficatIOns or dIscretIOnary
components to thIS aspect of ArtIcle 31 4
The InterpretatIOn suggested by the Umon would, In effect, create an exceptIOn to the
reqUIrement of geographIc proxImIty I see nothIng In the language of ArtIcle 31 to suggest that
such an exceptIOn should be read Into the agreement. Indeed, It would be surpnsIng If the
Employer could elect to umlaterally Waive the restnctIOns set out In 31 4 by the language It
chose to descnbe the locatIOn of the vacancy As the Umon qUIte nghtly notes, the Job PostIng
document IS created by the Employer and the InterpretatIOn advanced by the Umon would enable
the Employer to determIne on ItS own ImtIatIve when and whether the negotIated geographIc
postIng areas would be operatIve
In my VIew a plaIn readIng of the relevant provIsIOns of the collectIve agreement supports the
Employer's posItIOn that to be elIgIble for a vacancy the vacancy must anse In the casual
employee's geographIc area. The only "geographIc area" contemplated by ArtIcle 31IS that
defined by the partIes as the GeographIc PostIng Area, It IS sImply not open to either party to
SubstItute some other defimtIOn for that whIch has been JOIntly decIded. Undoubtedly It was
open to the partIes to define "geographIc area" broadly or narrowly or to agree on multIple
defimtIOns and leave It to the dIscretIOn of the Employer as to whether the locatIOn, and hence
elIgIbIlIty wIll be a general area, such as Area J or store specIfic In the end they have
proceeded to define the relevant geographIc area by reference to IndIVIdual stores and not
desIgnated areas The combIned effect of ArtIcle 31 and the partIes' own defimtIOn of
geographIc area precludes me from acceptIng the Umon's arguments Area J IS not a defined
GeographIc PostIng Area and cannot be used to extend the avaIlable pool of elIgIble applIcants In
a manner that IS InCOnsIstent WIth ArtIcle 31 4
In support of ItS posItIOn, the Umon has argued that It IS ImperatIve that the postIng and selectIOn
process be fair and transparent. As I suggested earlIer I am sympathetIc to the need for
transparency IdentIfied by the Umon and agree that It IS essentIal that the selectIOn process be
fair and be perceIved to be so I also accept that potentIal applIcants should be able to rely on the
Job PostIng and that they are entItled to certaIn basIc partIculars In the notIce of the vacancy
ArtIcle 21 4 outlInes the mImmum content reqUIred of the Job PostIng and Includes the dIrectIve
that the locatIOn of the vacancy be IdentIfied. The Umon dId not ask me to find that the
12
Employer faIled to comply wIth the terms of ArtIcle 21 4 Indeed, theIr submIssIOn was
contIngent on the Employer's dIscretIOn to IdentIfy the locatIOn as broadly as they have
SInce I was not asked to address the adequacy of the Job PostIng, I wIll refraIn from makIng any
findIngs In thIS regard. I wIll note, however that whether or not It constItutes a breach of ArtIcle
21 4 a faIlure to IdentIfy the exact locatIOn of the vacancy does InVIte confusIOn and
dISappOIntment. GIven that elIgIbIlIty IS determIned by reference to an applIcant's proxImIty to
the geographIc locatIOn of the vacancy the process mIght be better served If applIcants knew the
preCIse store where the vacancy wIll be filled before they put In theIr applIcatIOn.
In any event, despIte my sympathy for the general arguments raised by the Umon, I have
concluded that the collectIve agreement does not permIt the remedy requested. Nor do I thInk
that the facts of thIS case otherwIse warrant Interference wIth the Employer's selectIOn. In
arnvIng at thIS conclusIOn, I am satIsfied that the Employer acted In good faith In selectIng the
ultImate locatIOn and the IndIVIdual applIcants to fill these vacanCIes and that It acted In
accordance wIth the collectIve agreement. There IS no eVIdence to suggest that the Employer
acted for any Improper purpose, that It was motIvated by favountIsm or ammus wIth regard to
any of the IndIVIdual applIcants or that ItS decIsIOn to sItuate the vacanCIes at Stores 353 and 390
was for any reason other than legItImate busIness consIderatIOns I also find that management
elected to desIgnate Area J as the locatIOn of the vacancy to encourage the wIdest possIble pool
of applIcants that mIght be elIgIble for the posItIOn and therefore acted to preserve, not lImIt, the
potentIal entItlements of ItS casual employees
There was ample InfOrmatIOn avaIlable to casual employees to alert them to the lImIts of theIr
elIgIbIlIty On ItS face, the Job PostIng IndIcated that "the area of search wIll be the geographIcal
postIng area" and further that "Casual candIdates wIll be selected In accordance wIth the
provIsIOns under ArtIcle 31 4 of the CollectIve Agreement." The Job PostIng reInforced the
restnctIve elIgIbIlIty of casual employees and explIcItly referred to ArtIcle 31 4 It further
IndIcated that the area of the search would be the geographIc postIng area. In these
cIrcumstances, I find that the Job PostIng dId not prejUdICe the gnevor In any way She knew that
she was potentIally elIgIble for the vacancy and she applIed for the posItIOn. There was no
eVIdence to suggest that the gnevor or anyone else, consIdered the use of the broader letter
desIgnated area, Area J to have expanded her elIgIbIlIty or that she relIed on that belIef to her
13
detnment. I apprecIate that she was dIsappoInted when It was revealed that the final locatIOns
chosen for these posItIOn were at stores that were not wIthIn her geographIc postIng area,
however It was not arbItrary dISCnmInatory or unfair to her to proceed In thIS manner
I have concluded that ArtIcle 31 4 lImIts the gnevor's entItlement to permanent posItIOns WIthIn
her geographIc area. The partIes have defined the boundanes of the geographIc postIng area and
they have done so by reference to specIfic stores and not large, general areas The Employer was
not oblIged to consIder the gnevor for thIS vacancy and It acted properly In selectIng applIcants
who were employed as casuals at stores wIthIn the GeographIc PostIng Area for vacanCIes at
Store 390 and 353
In arnvIng at my conclusIOn I have carefully consIdered the cases provIded to me by counsel As
they candIdly conceded In argument, none of the cases are dIrectly on pOInt and ultImately I dId
not find that they were of much assIstance ThIS IS not a case where the employer sought to
amend, Ignore or otherwIse alter the qualIficatIOns used In selectIng candIdates as was the case In
a number of the cases cIted by the Umon (Fletcher Nipissing Mt. Sinai and Hotel Dieu) The
Employer's decIsIOn regardIng the locatIOn of the vacancy was not one that went to
qualifications reqUIred to perform the job at Issue Although the Employer's chOIce oflocatIOn
clearly affected eligibility It IS not comparable to a retroactIve change to the reqUIred
qualIficatIOns As I have already concluded, the lImItatIOns on elIgIbIlIty that were applIed by the
Employer flow dIrectly from the collectIve agreement and are not Independent qualIficatIOns
Nor IS thIS case analogous to the cases provIded by the Employer The Employer dId not attempt
to cancel the job competItIOn or correct an error contaIned In the postIng document. The
Employer acted delIberately In order to allow Itself the tIme and fleXIbIlIty It consIdered
necessary before choOSIng the optImal locatIOn for the newly created posItIOn. A general vacancy
was posted, wIth the specIfic sIte of the vacancy determIned at a later stage In the process There
was no mIstake In the postIng that the Employer subsequently tned to correct nor dId It move to
cancel the vacancy Arguably the Job PostIng lacked sufficIent partIculars, however at no tIme
has the Employer sought to rectIfy any deficIency
In the end, thIS case turns on the language found In ArtIcle 31 4 and the rather umque
CIrcumstances of the GeographIc PostIng Area at Issue In the vast majonty of po stIngs where the
14
employer mIght descnbe the vacancy In sImIlar terms, there would be full recIprocIty and any
employee wIthIn the desIgnated letter area would be elIgIble to apply at any other store wIthIn
that area. It IS the exceptIOnal sItuatIOn where the general letter desIgnatIOn does not correspond
to the GeographIc PostIng Areas agreed to by the partIes Although the partIes have not defined
them as Interchangeable terms, they are, for practIcal purposes, by and large complementary
Regrettably thIS gnevor IS a casual employee at a store wIth a more lImIted GeographIc PostIng
Area and one that crosses boundanes across regIOns and dIstncts Consequently the general
postIng Area that Includes her home store does not make her elIgIble for all stores In that Area.
In cloSIng argument, the Umon also requested that the second vacancy be over turned on the
basIs that It was not filled as a consequence of ItS own Job PostIng. I agree wIth the Employer
that the Umon' s request IS beyond the scope of thIS gnevance I have already determIned that the
Employer acted properly In determInIng that the gnevor was not elIgIble for consIderatIOn for
eIther vacancy The concerns raised by the Umon may properly form the basIs for another
separate gnevance, however It does not advance the cause of thIS gnevor and I would therefore
declIne to consIder It further
15
Conclusion
For the reasons provIded, I would dIsmIss the gnevance The gnevor IS not elIgIble for eIther
vacancy awarded as a consequence of the Job PostIng at Issue
Issued at Toronto thIS 31st day of March 2005
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Reva DevIns
Vice-Chair