HomeMy WebLinkAbout2003-4112.Union Grievance.04-05-03 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
~-,...
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# 2003-4112
UNION# 2004-0999-0010
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 In RIght of Ontano
(Mimstry of Energy) Employer
BEFORE Richard Brown Vice-Chair
FOR THE UNION GavIn Leeb
BarrIster and SOlICItor
FOR THE EMPLOYER DavId Strang
ActIng AssocIate DIrector
Management Board Secretanat
HEARING Apnl1 & 16 2004
2
DeCISIon
ThIS umon gnevance, dated March 24, 2004, anses out of the transformatIOn of the
Ontano Energy Board (OEB) from a component of the Mimstry of Energy to an
agency outsIde the Ontano Pubhc ServIce Pubhc servants who worked for the
OEB as part of the MmIstry were offered Jobs by the new agency Based upon the
premIse that these offers do not permIt semonty to be "carrIed over" wItllln the
meanmg of artIcle 6 0 of AppendIx 18 to the collectIve agreement-a premIse
contested by the employer-the umon claims the employees concerned are entItled
to exerCIse the nghts contamed m artIcle 20 of the collectIve agreement and
paragraphs 2 to 5 of AppendIx 9 ThIS award deals exclusIvely wIth the employer's
prehmmary ObjectIOn that the gnevance was not filed wIthm the apphcable tIme
InllI t
I
A labour-management commIttee was created to address Issues relatmg to the
transfer and members of the commIttee met approxImately once a month from
September of2003 to March of2004 Between December and early Febnlary, the
umon was gIven a senes of at least four draft transfer agreements between the
MmIstry of Energy and the new agency The final agreement was provIded to the
umon on February 9 The transfer took place on March 26, 2004
Dunng the months precedmg the transfer, both umon commIttee members
and the workforce at large were told consIstently by management that ItS objectIve
was to negotIate an agreement wIth the new OEB whIch would ensure that
transferrmg employees receIved at least 85% of theIr prevIOus earnmgs and
allowed OPS semonty and servIce to be carned over In the end, employees
actually enjoyed a pay mcrease when they moved to the receIvmg agency
3
The umon's pnmary concern underlymg the gnevance relates to a lImItatIOn
on the posItIOns that first must be posted and then filled on the basIs of semonty
where the qualIficatIOns of applIcants are "relatIvely equal" In the first draft
agreement, provIded to the umon m December of 2003, the new OEB undertook to
post Jobs only m "tYPIcal cIrcumstances" In response to questIOns asked by the
umon representatIves about the meanmg of "tYPIcal cIrcumstances", later verSIOns
of the transfer agreement lIsted a number of examples where Jobs would not be
posted. One of these exceptIOns IS of partIcular concern to the umon "a new
posItIOn and/or functIOnal area, such as payroll/ HR or controller, whIch dId not
eXIst before"
ThIS exceptIOn appears m the final transfer agreement Paragraph 11 1 of
Schedule C to the agreement states
Where the OEB determmes that a vacancy eXIsts m a regular full-tIme
posItIOn, It shall, m tYPIcal cIrcumstances, post the vacancy for at least
fifteen (15) days pnor to the closmg date The postmg shall mclude the Job
tItle, locatIOn, salary range, a general descnptIOn of the Job dutIes
qualIficatIOns and any other mformatIOn the OEB deems relevant For the
purpose of Schedule C, sItuatIOns such as the followmg are examples of
when It may be deemed not to be a tYPIcal cIrcumstance, for example, when
there IS a known and chromc scarcIty for a set of qualIficatIOns for a
partIcular type of work, when a qualIfied candIdate has been IdentIfied from
another competItIOn, completed wItllln the prevIOUS 12 months, for a
posItIOn WIth substantIally sImIlar reqUIrements and selectIOn cntena, when
an assIgnment IS made m accordance wIth the staff planned career
progressIOn/ development and IS supported by an mdIvIdual development and
trammg plan, when a full tIme posItIOn IS bemg converted to part tIme (or
VIce versa) for operatIOnal or compassIOnate reasons, where an employee
requests and the employer agrees for a transfer to a vacant posItIOn for health
reasons or on compassIOnate grounds, where a new posltzon and or
functzonal area, such as payroll HR or controller, whlch dld not eXlst
before (emphasIs added)
The subject of Job postmgs was also canvassed m an "employee gUIde"
prepared by the new OEB and delIvered to employees on March 8, 2004 along
wIth theIr Job offers The gUIde mdIcates the reqUIrement to post a posItIOn would
4
not apply "where a new posItIOn and/or functIOnal area dId not eXIst before" There
IS no reference m the gUIde to payroll, human resources or controller When UnIon
representatIves vOIced a concern that tlllS exceptIOn to the postmg reqUIrement was
worded dIfferently m the gUIde than m the transfer agreement, the new OEB Issued
a memorandum to all employees statmg "the [transfer agreement and ItS
schedules] are attached as they are referenced m the Employee GUIde dated March,
2004 In case of amblgUlty, the superlOr benefit prevazls" (emphasIs added) ThIS
memorandum was mtended to reassure employees that the new agency would
comply wIth the transfer agreement
II
The transfer of operatIOns from the MinIstry of Energy to the new OEB IS
governed by artIcle 6 of AppendIx 18 to the collectIve agreement, the relevant
parts of whIch state
6 1 1 For all Schedule B transfers, excludmg those covered by ArtIcle 6 3,
the employer wIll propose m negotIatIOns wIth the receIvmg employer that
Job offers shall be at a salary of at least 100% of the respectIve employee's
weekly salary at the tIme of the transfer and recognIze the servIce and
senIonty m the Ontano Pubhc ServIce (OPS) of each employee for the
purpose of quahficatIOn for vacatIOn, benefits (except pensIOn), layoff and
Job competItIOn, severance and tennmatIOn payments to the extent that they
are provIded m the proponent's workplace or If none, the OPS
6 1 2 The Employer agrees that m any negotIatIOns wIth the receIvmg
employer It IS to be understood that the employer wIll request that
employees of the Crown who are transferred under ArtIcle 6 0- NegotIated
Transfers should not be reqUIred to serve a probatIOnary penod wIth the new
employer
6 2 1 In the event that a receIvmg employer does not fully agree to the
request m artIcle 6 1 1, mcludmg the matter of a probatIOnary penod, the
employer may offer the receIvmg employer a financIal mcentIve up to the
amount that would have been payable as enhanced severance pay (calculated
as provIded m paragraph 4 of AppendIx 9) to each employee affected by the
transfer that the employer determmes wIll be declared surplus, m order to
5
secure or Improve a Job offer to the employee eqUIvalent to a Job offer as
described m ArtIcle 6 1 1 above or to ensure where Job offers are receIved
from the receIvmg Employer for less than the full complement of employees
IdentIfied by the Employer, that the receIvmg Employer offer employees
Jobs on the basIs of senIonty
6 5 If an employee refuses a Job offer whIch provIdes a salary of at least
85% of the respectIve employee's weekly salary at the tIme of the transfer
and recognIzes the serVIce and senIonty m the Ontano PublIc ServIce (OPS)
of each employee for the purpose of qualIficatIOn for vacatIOn, benefits
(except pensIOn), layoff, Job competItIOn, severance and tennmatIOn
payments to the extent that they are provIded m the proponents workplace,
the employee shall be deemed to have resIgned effectIve the date of the
transfer of theIr Job and no other prOVISIOn of the collectIve agreement wIll
apply except for ArtIcle 53 or 78 (TennmatIOn Pay)
6 6 Where the salary of the Job offered by the receIvmg employer IS less than
eIghty-five percent (85%) of the employee's current weekly salary, or If the
employee's servIce or senIonty are not carrIed over to the receIvmg
employer, the employee may declIne the offer In such a case, the employee
may exerCIse the nghts prescribed by ArtIcle 20 (Employment StabIlIty)
and/or paragraphs 2 to 5 of AppendIx 9
The gnevance contends the Job offers made to employees do not allow
senIonty to be carrIed over wItllln the meanmg of artIcle 6 6, m the sense that,
although employees wIll carryover theIr OPS senIonty m general, they wIll not be
able to use It to bId on any Jobs filled by the new agency wIthout a postmg
III
What tIme lImIt applIes to the filIng of thIS gnevance? AppendIx 18 contams two
dIspute resolutIOn procedures, each wIth ItS own 11lnItatIOn penod for gnevances
Some dIsputes are governed by artIcle 4.2 and others by artIcle 8 0
ArtIcle 4 2 states
The partIes agree that dlsputes that arzse regardzng the znterpretatzon or
applzcatzon of th,S agreement that are unresolved at Stage 1 of the gnevance
process wIll proceed as follows
6
On Its face, tlus artIcle apphes to "dIsputes that anse regardmg the mterpretatIOn or
apphcatIOn of thIS agreement" [1 e AppendIx 18] For such dIsputes, artIcle 4 2
modIfies some aspects of the normal gnevance process, but leaves unaltered the
tune hmIt of thIrty days for the filmg of UnIon gnevances, as found m artIcle
22 13 1
22 13 1 Where any dIfference between the Employer and the UnIon anses
from the mterpretatIOn, apphcatIOn, admmIstratIOn or alleged contraventIOn
of the Agreement, the UnIon shall be entItled to file a gnevance at the
second stage of the gnevance procedure provIded It does so wIthm thIrty
(30) days followmg the occurrence or ongmatIOn of the CIrcumstances
gIvmg nse to the gnevance
It IS common ground that "days" for thIS purpose do not mclude Saturdays,
Sundays and desIgnated hohdays by vIrtue of artIcle 22 14.2 Accordmg to the
UnIon, the tune hmIt m artIcle 22 13 1 apphes to the mstant gnevance
ArtIcle 8 0 prescnbes a dIfferent process for resolvmg some dIsputes under
AppendIx 18 ThIS artIcle states
8 1 All dIsputes ansmg out of ArtIcle 5 0,6 0 or 6C 0 must be detennmed
pursuant to ArtIcle 8 0 Any other gnevances under thIS agreement wIll go
through the dIspute resolutIOn process m ArtIcle 4.2
8 2 When the Employer releases a tender under Schedule A or C, the
Employer agrees that OPSEU wIll be provIded wIth a copy of the RFP that
the MmIstry has released. If OPSEU beheves that the tender IS not m
comphance WIth eIther ArtIcle 5 0 or ArtIcle 6C 0 as appropnate, OPSEU
may refer the matter to medIatIOn/arbItratIOn and the matter must be resolved
15 days pnor to the closmg of the tender
8 3 When the employer sIgns a transfer agreement wIth a hospItal,
mUnIcIpahty or other employer m respect to transfers under Schedule B, the
employer agrees that OPSEU wIll be provIded wIth a copy of the transfer
agreement that the employer has sIgned wIth the mUnIcIpahty, hospItal or
other receIvmg employer If OPSEU beheves that the transfer agreement IS
not m comphance WIth ArtIcle 60, OPSEU may refer the matter to
medIatIOn/arbItratIOn wItlun a seven (7) calendar day tune penod and the
matter must be resolved wIthm that tIme penod.
7
The mmIstry contends the gnevance IS governed by artIcle IS 8 3 whIch allows
only seven calendar days, not Just for fihng a gnevance, but for resolvmg the
underlymg dIspute
IV
Does tlus gnevance fall under artIcle 4 2, wIth a tune hmIt of tlurty workmg days
for launchmg a gnevance, or under artIcle 8 3 wIth a tIme hmIt of seven calendar
days for resolvmg a dIspute?
Notmg artIcle 8 1 states "all dIsputes ansmg out of ArtIcle 60 must be
detennmed pursuant to ArtIcle 8 0", employer counsel asserts the current dIspute,
about the apphcatIOn of artIcles 6 5 and 6 6 to Job offers, IS a dIspute "ansmg out
of' artIcle 6 0 Counsel also contends the purpose of artIcle 8 0 IS to ensure all
dIsputes relatmg to a transfer are resolved before the transfer takes place
Accordmg to thIS argument, It would make no sense to resolve some Issues wIthm
seven calendar days If gnevances about related matters need not be filed for thIrty
workmg days Counsel submItted It IS reasonable to assume offers made to
employees by a receIvmg employer wIll comply wIth the precedmg transfer
agreement 1 e that an agreement specIfymg terms and condItIons of employment
meetmg the cntena m artIcle 6 5 wIll result m matclung Job offers In the unlikely
event the offers actually made to employees were less generous than the associated
transfer agreement, somethmg whIch tYPIcally would not be known wIthm seven
days of the agreement bemg provIded to the UnIon, counsel for the employer
suggested there would be grounds for the extensIOn of tune for a gnevance
contendmg employees were entItled to exerCIse the nghts specIfied m artIcle 6 6
because the offers were deficIent
8
Umon counsel emphasIzes the gnevance at hand challenges neIther the
contents of the transfer agreement nor the efforts made by the employer when
negotIatmg It In other words, the umon does not allege a vIOlatIOn of artIcle 6 1 or
62 1 Counsel concedes the seven-day tIme would apply to a gnevance, based
upon eIther of these artIcles, contestmg the terms of the agreement or the effort put
mto It The tune hmIt m artIcle 8 3 IS Said not to apply to the mstant gnevance
about the employer's charactenzatIOn of Job offers as meetmg the cntena m artIcle
6 5 and the consequent demal of nghts specIfied m artIcle 6 6 Addressmg a
scenano where the transfer agreement reqUIres the terms and condItIons of
employment specIfied m artIcle 6 5, and where the umon learns after the expIry of
the tIme hmIt m artIcle 8 3 that Job offers fall short of thIS mark, umon counsel
asserts the collectIve agreement should not be mterpreted so as to preclude a
gnevance unless an arbItrator can be persuaded to extend the tIme for filmg one
In reply, employer counsel argues the current gnevance, allegmg Job offers
matclllng the transfer agreement do not meet the cntena m artIcle 6 5, IS m essence
a gnevance contendmg the transfer agreement does not comply wIth that artIcle
V
There are two cases deahng wIth the apphcatIOn of the seven-day tIme hmIt m
artIcle 8 3 In Mlnlstry afHealth and OPSEU, GSB No 1495/00, decIsIOn dated
January 24, 2002, I held thIS hmItatIOn penod apphed to a umon gnevance
contendmg the employer had vIOlated artIcle 6 0 by not makmg sufficIent efforts to
persuade the receIvmg employers to leave transferred employees m the OPSEU
PenSIOn Trust I wrote
ArtIcle 14 of the transfer agreements, as provIded to the umon m the early
months of 2000, allowed the receIvmg hospItals to choose between HOOPP
and OPT Not untIl September of 2000 dId OPSEU learn the hospItals had
chosen HOOPP Yet the root of the umon's present complamt agamst the
Crown, under artIcle 6 0, resIdes not m the chOIce made by the hospItals but
9
m the transfer agreements whIch left thIS optIOn open to them If the umon's
mterpretatIOn of artIcle 6 0 prevails, the provmce would be reqUIred to
endeavour to negotIate wIth the hospItals to estabhsh a new pensIOn
arrangement whIch would supersede artIcle 14 of the transfer agreements In
short, the essence of the umon' s argument IS that the agreements themselves
contravene artIcle 6 0 The purpose of the stnct tIme hmIt m artIcle 8 3 IS to
ensure the expedItIous resolutIOn of dIsputes, such as those at hand, about
whether a transfer agreement does comply wIth artIcle 6 0 ThIS analysIs
leads me to conclude artIcle 8 3 apphes to these gnevances msofar as they
are based on artIcle 6 (pages 6 and 7)
ArtIcle 8 3 was agam apphed mMlnlstry afHealth and OPSEU, GSB No
2003-0337, decIsIOn dated March 8, 2004 (Petryshen) In that case, the transfer
agreement was provIded to the umon m February of 2000 but the transfer dId not
occur untIl June of 2003 The umon learned m late Apnl of 2003 that the employer
had not paid a financial mcentIve to the receIvmg hospItal and thIS dIsclosure led to
a gnevance bemg filed at the begmnmg of May VIce-Chair Petryshen wrote
The payment of the financial mcentIve only becomes an Issue If the
Employer IS unable to secure from the receIvmg hospItal the OPS tenns and
condItIons of employment as reflected m SectIOn 6 1 1 The payment of the
financial mcentIve IS to assIst the Employer m obtammg Job offers that
reflect as closely as possible the OPS terms and condItIons of employment
The remedy the Umon seeks m tlus mstance Illustrates the relatIOnslup
between SectIOns 6 1 1 and 6 2 1 In addItIon to requestmg that the
Employer be dIrected to offer the financial mcentIve to St Joseph's, the
Umon seeks an order dIrectmg the Employer to attempt to negotIate wIth St
Joseph's to attam tenns and condItIons of employment m certam areas whIch
mIrror the terms and condItIons of the OPS agreement
SectIOn 8 1 provIdes that all dIsputes ansmg out of ArtIcle 6 0 must be
detennmed pursuant to ArtIcle 8 0, whIch of course mcludes SectIOn 8 3 and
the stnngent tIme hmIts contamed therem The Umon's allegatIOn that the
Employer dId not pay the financial mcentIve IS a dIspute whIch anses out of
ArtIcle 6 0 The fact that the Umon was told m Apnl 2003 of the Employer's
failure to pay the financial mcentIve does not mean that ItS obhgatIOn to
challenge the Transfer Agreement dId not anse m Febnmry 2000, wIthm the
tune hmIt set out m SectIOn 8 3 The presence of certam SectIOn 6 1 1
Issues and the absence of an mdIcatIOn m the Transfer Agreement that a
financial mcentIve would be paid to St Joseph's IS a reasonable basIs upon
whIch the Umon could have concluded m February 2000 that no financial
10
mcentIve had been paid to St Joesph's and that the Transfer Agreement was
not m complIance wIth ArtIcle 6 0 Even If the absence of any reference to
the payment of a financial mcentIve m the Transfer Agreement, by Itself, IS
not a basIs for concludmg that there has been a potentIal contraventIOn of
SectIOn 6.2 1, such an absence, m the face of certam SectIOn 6 1 1 Issues,
should have caused the Umon to mqUIre about whether the financIal
mcentIve had been offered to St Joseph's (pages 9 to 11)
In both of these cases, the umon contended the terms and condItIons of
employment specIfied m the transfer agreement were madequate because the
employer had not made sufficIent efforts to persuade the receIvmg enterpnse to
make Job offers more favourable to employees The remedy sought m each case
was an order dIrectmg the employer to renegotIate the agreement m an attempt to
Improve terms and condItIons of employment The seven-day lImIt m artIcle 8 3
for resolvmg a dIspute was held to apply to these matters
ArtIcle 8 3 speaks of dIsputes about whether a "transfer agreement" IS "m
complIance wIth artIcle 6 0 "In the two cases dIscussed above, the short tIme lImIt
m artIcle 8 3 was applIed, even though the vIOlatIOn asserted m the gnevance lay
not m the alleged madequacy of the transfer agreement Itself, but m the employer's
allegedly msufficIent attempt to secure a better deal for employees If the employer
had made the efforts reqUIred by artIcles 6 1 and 6 2 1, but faIled to persuade the
receIvmg enterpnse to ennch the terms and condItIons of employment, there would
have been no contraventIOn of artIcle 6 0, despIte any deficIencIes m the
agreement ThIS IS why the vIOlatIOn alleged concerned the employer's approach to
bargammg, not merely the contents of the agreement Itself
In my VIew, readmg artIcle 8 3 as applymg to dIsputes about whether the
employer's conduct at the bargammg table complIes wIth artIcle 6 0 IS fully
warranted, even though thIS artIcle speaks of a transfer agreement not complymg
wIth artIcle 6 0 In the two cases dIscussed above, the remedy sought was the re-
opemng of negotIatIOns m the hope of changmg the agreement In other words, a
dIspute about the adequacy of the agreement underlay the gnevance m each case
11
Moreover, constnllng artIcle 8 3 as applymg only to gnevances solely about the
contents of a transfer agreement would render the seven-day tune mapplIcable to
dIsputes ansmg from artIcles 6 1 and 6.2 1, two prOVISIOns at the heart of artIcle
6 0 ArtIcles 6 1 and 6.2 1 specIfy what efforts the employer must make when
negotIatmg a transfer agreement, but notlllng m artIcle 6 0 specIfies any cntena
that such an agreement must meet
Under artIcle 8 3, tIme begms to run when a transfer agreement IS provIded
to the UnIon ThIS temporal startmg pomt IS appropnate m the context of a dIspute
about the sufficIency of the employer's efforts A startmg pomt before the
agreement IS complete would make no sense, because there would be lIttle pomt m
the UnIon contestmg the propnety of management's conduct before knowmg the
contents of the resultmg agreement The ratIOnale for reJectmg a later startmg pomt
IS explamed m the above excerpt from the decIsIOn of VIce-Chair Petryshen Once
the UnIon knows the agreement does not meet ItS expectatIOns, It can make
mqUInes about the employer's efforts and decIde whether a gnevance IS warranted
VI
Does the tune lImIt m artIcle 8 3 apply to the current dIspute about how artIcle 6 0
applIes to the Job offers made by the new OEB?
ArtIcles 6 5 and 6 6 do not specIfy cntena that Job offers must satIsfy
Instead, these artIcles detennme what nghts under the collectIve agreement an
employee IS entItled to exerCIse, If he or she declmes a Job offer from the receIvmg
enterpnse, wIth the determmatIOn of contractual entItlements bemg based upon the
content of the offer If the salary offered IS at least 85% of the employee's current
earnmgs, and If OPS senIonty and servIce are to be carned over, then the
employee's only entItlement under the collectIve agreement IS to receIve
tennmatIOn pay, accordmg to artIcle 6 5 If the offer IS less generous m relatIOn to
12
salary or semonty and servIce, artIcle 6 6 entItles the employee to the benefit of
artIcle 20 of the collectIve agreement and paragraphs 2 to 5 of AppendIx 9
In tlllS contractual context, It makes no sense to speak of Job offers
"complymg" wIth artIcle 6 5 or 6 6 The reason IS these artIcles contam no
reqUIrements wIth whIch such offers are expected to comply Instead, artIcles 6 5
and 6 6 dehneate two possible categones of Job offers and specIfy the entItlements
under the collectIve agreement of an employee who dechnes an offer of each type
The umon contends employees who declmed a Job offer were entItled to
exerCIse the nghts specIfied m artIcle 6 6, because the Job offers dId not entaIl a
carryover of semonty wIthm the meanmg of that artIcle Contendmg the offers
allowed semonty to be carrIed over, the employer submIts the refusal of a Job offer
would have dIsentItled an employee to all benefits under the collectIve except
termmatIOn pay, accordmg to artIcle 6 5 ThIS IS substantIve dIspute between the
partIes
ThIS sort of dIspute, about the quahty of Job offers, does not readIly fit the
type described m artIcle 8 3 1 e dIsputes about whether a "transfer agreement" IS
"m comphance WIth artIcle 6 0 " The fit would be poor for any case of thIS sort,
even though the terms of Job offers tYPIcally reflect those specIfied m the
associated transfer agreement NeIther Job offers nor transfer agreements can be
sensIbly labelled as complymg, or not complymg, wIth artIcles 6 5 or 6 6 Rather
than regulatmg the content of Job offers themselves, these artIcles dIvIde all
logIcally possIble offers mto two types and detennme what entItlements flow when
offers of eIther type are dechned. The content of Job offers per se IS ungoverned by
artIcle 6 0, unlike the employer's conduct when negotIatmg a transfer agreement
whIch IS regulated by artIcles 6 1 and 6 2 1 ThIS dIstmctIOn renders the two cases
dIscussed above mapphcable to the facts at hand.
The occurrence that commences the nmnmg of tIme under artIcle 8 3-the
dehvery of a transfer agreement to the umon-makes no sense for some dIsputes
13
that mIght anse under artIcles 6 5 and 6 6 In partIcular, thIS startIng pOInt would
be IllogIcal In a case where Job offers made to employees do not match the transfer
agreement WhIle such offers usually mIrror the precedIng agreement, there IS no
guarantee the two wIll be the same Offers tYPIcally are made much later than
seven days after dehvery of the transfer agreement In a case where the transfer
agreement leads the umon to expect Jobs to be offered on the terms descnbed In
artIcle 6 5, and the employer treats employees accordIngly, but where the offers
eventually made are of the sort described In artIcle 6 6, any gnevance about the
treatment of employees would be untImely under artIcle 8 3, even If the umon
gneved as soon as the Job offers were receIved. It seems unlikely those who
negotIated AppendIx 18 Intended such an outcome, one that would force the umon
to rely exclusIvely upon an arbItrator to extend the tune for fihng a gnevance
ThIS analysIs leads me to reject the employer's InterpretatIOn of artIcle 8 0
and to conclude the tIme hmIt In artIcle 8 3 does not apply to the Instant gnevance
NotwIthstandIng the sweepIng language of artIcle 8 0, saYIng It apphes to all
dIsputes ansIng out of artIcle 6 0, the most reasonable constructIOn of the wordIng
of artIcle 8 3 IndIcates ItS seven-day tIme hmIt does not apply to thIS gnevance
VII
The apphcable tIme hmIt IS found In artIcle 22 13 1 As the partIes agree the
gnevance was filed wIth the penod specIfied by thIS artIcle, the employer's
prelunInary ObjectIOn IS dIsmIssed.
Dated at Toronto thIS 3rd day of May 2004
12
,rtd4--<-4 ~
/RIchard Brown
VIce-Chair