HomeMy WebLinkAbout2004-2081.Policy Grievance.05-03-29 Decision
Crown Employees Commission de ~~
Grievance Settlement reglement des griefs
Board des employes de la
Couronne
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GSB# 2004-2081
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 Ontano
(PolIcy Gnevance) Association
- and -
The Crown In RIght of Ontano
(Management Board Secretanat) Employer
BEFORE Ken Petryshen Vice-Chair
FOR THE UNION Steven Barrett
Sack Goldblatt Mitchell
BarrIsters and SOlICItorS
FOR THE EMPLOYER Mary Gersht
Counsel
Management Board Secretanat
HEARING December 7 2004
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DeCISIon
After resolvIng an IndIVIdual gnevance In September 2004 the partIes agreed to address
a polIcy Issue relatIng to parental leave at a heanng on December 7 2004 Under the
Employment Standards Act, 2000 ("the ESA") an employee can take eIther 35 or 37 weeks of
parental leave after a bIrth or an adoptIOn. For the purposes of thIS decIsIOn, I wIll assume that
we are dealIng wIth an employee who IS entItled to 3 7 weeks of parental leave The Issue In
dIspute IS whether an employee who takes less than 3 7 weeks of parental leave and returns to
work for the Employer can then take another penod off as parental leave For example, can a
father take 12 weeks of parental leave, return to work for the Employer for 8 weeks, and then
take a further penod of up to 17 weeks as parental leave? The Umon takes the posItIOn that an
employee IS entItled to splIt up parental leave In thIS way and that the CollectIve Agreement and
the ESA permIt such a result. The Employer takes the posItIOn that an employee can only take
parental leave for one contInUOUS penod. In ItS VIew the CollectIve Agreement and the ESA
provIde that parental leave IS completed once an employee returns to work for the Employer
even If the employee dId not take hIS or her full entItlement. There was no challenge to my
JunsdIctIOn to hear and determIne thIS dIspute
The partIes dId not call oral eVIdence Counsel Introduced documents on consent and
made theIr submIsSIOns What IS at stake IS not only the nght to take an addItIOnal parental
leave but the benefits assocIated wIth parental leave An employee on parental leave IS entItled
to a "top-up" payment for a number of weeks and can contInue to partICIpate In benefit plans
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The Employer provIdes employees wIth a Pregnancy Parental and AdoptIOn Leave
InformatIOn Package ConsIstent WIth the posItIOn the Employer takes before me, thIS Package
refers to the consequences of returmng to work as follows
Return to Work Durin2 Leave Period
Any return to work wIll termInate the leave Subsequent leave may be granted -
under dIscretIOnary unpaid leave terms No entItlement to SUB-Allowance,
even If the employee contInues to receIve EI benefits
The submIssIOns of counsel focused on the parental leave provIsIOns In both the
CollectIve Agreement and In the ESA, wIth a recogmtIOn that the dIspute wIll ultImately be
resolved by an InterpretatIOn of the ESA ArtIcle 24 of the CollectIve Agreement deals wIth
pregnancy leave, parental leave and the employment Insurance top-up For our purposes, the
relevant provISIOns relatIng to parental leave are as follows
24 7 Parental Leave:
The Employer shall grant a leave of absence wIthout pay In accordance
wIth Part XIV of the Employment Standards Act, 2000 to an employee
who has at least thIrteen (13) weeks servIce WIth the Crown and who IS the
parent of a chIld.
24 8 Parental leave may begIn,
(a) no earlIer than the day the chIld IS born or comes Into custody care and
control of the parent for the first tIme and,
(b) no later than fifty-two (52) weeks after the day the chIld IS born or comes
Into the custody care and control of the parent for the first tIme
24 9 The parental leave of an employee who takes pregnancy leave must begIn
when the pregnancy leave ends unless the chIld has not yet come Into the
custody care and control of a parent for the first tIme
24 10 Parental leave ends thIrty-five (35) weeks after It began for an employee
who takes pregnancy leave and thIrty-seven (37) weeks after It began for
an employee who dId not take pregnancy leave An employee who has
gIven notIce to end parental leave may change the notIce
(a) to an earlIer date If the employee gIves the Employer at least four (4)
weeks wntten notIce before the earlIer date or
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(b) to a later date If the employee gIves the Employer at least four (4)
weeks wntten notIce before the date the leave was to end.
24 11 Employment Insurance Top-up
An employee who IS entItled to pregnancy/parental leave and who provIdes
the Employer wIth proof that he or she IS In receIpt of employment
Insurance benefits pursuant to the Employment Insurance Act (Canada)
shall be paid an allowance In accordance wIth the Supplementary Benefit
Plan.
24 13 In respect of the penod of parental leave, payments made accordIng to the
Supplementary Employment Benefit Plan wIll consIst of the folloWIng
(a) Where the employee serves the employment Insurance WaitIng penod,
for the first two (2) weeks, payments eqUIvalent to mnety-three percent
(93%) of the actual weekly rate of pay for hIS or her classIficatIOn, and shall
also Include any Increases In salary that he or she would have attaIned had he or
she been at work dunng the leave of absence as they are or would have been,
Implemented, and,
(b) for each week, up to a maXImum of fifteen (15) addItIOnal weeks,
payments eqUIvalent to the dIfference between the sum of the weekly
Employment Insurance benefits the employee receIves for the week and
any other salary earned by the employee dunng the week, and mnety-three
(93%) of the actual weekly rate of pay for hIS or her claSSIficatIOn, and shall
also Include any Increases In salary that he or she would have attaIned had he or
she been at work dunng the leave of absence as they are or would have been,
Implemented.
24 14 Payments under the Supplementary Employment Benefit Plan wIll not
apply to leave that contInues after fifty-two weeks folloWIng the day the
chIld IS born or comes Into the custody care and control of the parent for
the first tIme, where Employment Insurance benefits do not apply
NotwIthstandIng any other artIcle In thIS agreement, vacatIOn credIts and
semonty contInue to accrue dunng pregnancy leave (ArtIcle 24.2)
parental leave (ArtIcle 24 7) and extended leaves (ArtIcle 24 17 and 24 19)
ContInuous servIce for severance accrues dunng pregnancy and parental
leave except dunng the last SIX (6) weeks of unpaid leave folloWIng
parental leave for a bIOlogIcal father or adoptIve parent.
24 15 Benefit Plans
Dunng pregnancy leave, parental leave and extended leave, an employee
who partICIpates In the Benefit Plans referred to In ArtIcles 31 to 36 shall
contInue that partICIpatIOn unless he or she elects In wntIng not to do so
(a) Where an employee elects to contInue to make hIS or her penSIOn
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contnbutIOns under eXIstIng practIce, pensIOnable servIce shall also
accrue and the Employer shall contInue to make ItS contnbutIOns
(b) Extended leave IS only covered by thIS ArtIcle If the purpose of the
extensIOn IS dIrectly related to parental leave taken by a bIOlogIcal
father or adoptIve parent.
24 16 Unless an employee gIves the Employer wntten notIce referred to In
ArtIcle 24 15 the Employer shall contInue to pay the premIUms for the
Benefit Plans In ArtIcles 31 to 36 that the Employer was paYIng
Immediately before the Employee's pregnancy leave parental leave and
extended leave and the employee shall contInue to pay the premIUms for
the group Insurance coverages that the employee was paYIng
ImmedIately before the pregnancy leave or parental leave
24 17 Pregnancy plus Parental Leave:
An employee on pregnancy leave IS entItled to a parental leave of
absence of up to thIrty-five (35) weeks
24 18 Parental leave for an employee who also took pregnancy leave shall
commence ImmedIately folloWIng the expIry of the pregnancy leave
24 19 Extension of Parental Leave:
Except for an employee to whom ArtIcle 24 17 applIes, an employee on
parental leave IS entItled, upon applIcatIOn In wntIng at least two (2) weeks
pnor to the expIry of the leave, to a consecutIve leave of absence wIthout
pay and wIth accumulatIOn of credIts for not more than SIX (6) weeks
2420 An employee returmng to work after pregnancy leave, parental leave or
extended leave referred to In ArtIcles 24 19 or 24 22 shall be reInstated
to the posItIOn the employee most recently held wIth the Employer on a
regular and not a temporary basIs, If the posItIOn stIll eXIsts, or to a
comparable posItIOn, If It does not.
24 21 The Employer shall pay a reInstated person salary that IS at least equal to
the greater of;
(a) the salary the employee was most recently paid by the Employer or
(b) the salary that the employee would be earnIng had the person worked
throughout the leaves of absence referred to In ArtIcles 24 2, 24 7 24 19
or 24 22
2422 An employee who has worked less than thIrteen (13) weeks wIth the Crown
and becomes the parent of a chIld shall be granted upon request a leave of
absence wIthout pay and wIthout accumulatIOn of credIts and servIce under
dIscretIOnary leave provISIOns of ArtIcle 23.2 (Leaves of Absence) for up
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to the folloWIng pen ods
(a) fifty-two (52) weeks for an employee who would otherwIse be elIgIble
for pregnancy leave and parental leave under ArtIcles 24 2 and 247
and,
(b) forty-three (43) weeks for an employee who would otherwIse be
elIgIble for parental leave and extended leave only under ArtIcles
24 7 and 24 19
If otherwIse elIgIble, the employee IS entItled to contInue benefit coverage
dunng the leave by paYIng both the employee's and the Employer's share
of the premIUms
The above CollectIve Agreement proVIsIOns mIrror to a consIderable degree the parental
leave proVIsIOns In the ESA Of course It IS the proVIsIOns of the ESA whIch establIsh the
mImmum standards for parental leave In Ontano The relevant parental leave proVIsIOns In the
ESA are as follows
Parental Leave
48 (1) An employee who has been employed by hIS or her employer for at least
13 weeks and who IS the parent of a chIld IS entItled to a leave of absence
WIthout pay folloWIng the bIrth of the chIld or the comIng of the chIld Into
the employee's custody care and control for the first tIme
When leave may begIn
(2) An employee may begIn parental leave no later than 52 weeks after the
day the chIld IS born or comes Into the employee's custody care and
control for the first tIme
RestnctIOn If pregnancy leave taken
(3) An employee who has taken pregnancy leave must begIn her parental
leave when her pregnancy leave ends unless the chIld has not yet come
Into her custody care and control for the first tIme
N OtI ce
(4) SubJ ect to subsectIOn (6) an employee WIshIng to take parental leave
shall gIve the employer wntten notIce at least two weeks before the
day the leave IS to begIn.
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NotIce to change date
(5) An employee who has gIven notIce to begIn parental leave may begIn the
leave
(a) on an earlIer day than was set out In the notIce If the employee gIves the
employer a new wntten notIce at least two weeks before that earlIer day or
(b) on a later day than was set out In the notIce, If the employee gIves the
employer a new wntten notIce at least two weeks before the day set out
In the ongInal notIce
If chIld earlIer than expected
(6) If an employee stops workIng because a chIld comes Into the employee's
custody care and control for the first tIme earlIer than expected,
(a) the employee's parental leave begIns on the day he or she stops workIng;
and
(b) the employee must gIve the employer wntten notIce that he or she IS takIng
parental leave wIthIn two weeks after stoppIng work.
End of parental leave
49 (1) An employee's parental leave ends 35 weeks after It began, If the
employee also took pregnancy leave and 37 weeks after It began,
otherwIse
EndIng leave early
(2) An employee may end hIS or her parental leave earlIer than the day set
out In subsectIOn (1) by gIVIng the employer wntten notIce at least four
weeks before the day he or she wIshes to end the leave
ChangIng the date
(3) An employee who has gIven notIce to end hIS or her parental leave may
end the leave,
(a) on an earlIer day than was set out In the notIce If the employee gIves the
employer a new wntten notIce at least four weeks before the earlIer day or
(b) on a later day than was set out In the notIce, If the employee gIves the
employer a new wntten notIce at least four weeks before the day
IndIcated In the ongInal notIce
Employee not returmng
(4) An employee who takes parental leave shall not termInate hIS or her
employment before the leave expIres or when It expIres wIthout gIVIng
the employer at least four weeks' wntten notIce of the termInatIOn.
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ExceptIOn
(5) SubsectIOn (4) does not apply If the employer constructIvely dIsmIsses
the employee
GENERAL PROVISIONS CONCERNING LEA YES
Rights dunng leave
51 (1) Dunng any leave under thIS part, an employee contInues to partIcIpate In
each type of benefit plan descnbed In subsectIOn (2) that IS related to hIS or
her employment unless he or she elects In wntIng not to do so
Benefit plans
(2) SubsectIOn (1) applIes WIth respect to pensIOn plans, lIfe Insurance plans,
accIdental death plans, extended health plans, dental plans and any
prescnbed type of benefit plan.
Employer contnbutIOns
(3) Dunng an employee's leave under thIS Part, the employer shall contInue to
make the employer's contnbutIOns for any plan descnbed In subsectIOn (2)
unless the employee gIves the employer a wntten notIce that the employee
does not Intend to pay the employee's contnbutIOns, If any
ReInstatement
53 (1) Upon the conclusIOn of an employee's leave under thIS Part, the employer
shall reInstate the employee to the pOSItIOn the employee most recently
held WIth the employer If It stIll eXIsts, or to a comparable pOSItIOn, If It
does not.
ExceptIOn
(2) SubsectIOn (1) does not apply If the employment of the employee IS ended
solely for reasons unrelated to the leave
Wage rate
(3) The employer shall pay a reInstated employee at the rate that IS equal to
the greater of,
(a) the rate that the employee most recently earned WIth the employer and
(b) the rate that the employee would be earmng had he or she worked
throughout the leave
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I also was referred to the provIsIOns relatIng to parental benefits In the Employment
Insurance Act ("the EIA") Under the EIA an employee can be off work collectIng EI parental
benefits, return to work for hIS or her employer and then be off work agaIn collectIng EI parental
benefits S 23 (2) of the EIA provIdes as follows
Parental benefits
23 (2) SubJect to sectIOn 12, benefits under thIS sectIOn are payable for each week
of unemployment In the penod
(a) that begIns wIth the week In whIch the chIld or chIldren of the claimant are
born or the chIld or chIldren are actually placed wIth the claimant for the
purpose of adoptIOn, and
(b) that ends 52 weeks after the week In whIch the chIld or chIldren of the
claimant are born or the chIld or chIldren are actually placed wIth the
claimant for the purpose of adoptIOn.
In support of the posItIOn that an employee cannot take a parental leave, return to
work for the Employer and then take another parental leave dunng whIch the employee
collects the top-up payment, counsel for the Employer relIed on the language In the CollectIve
Agreement and the ESA Counsel submItted that the Employer's practIce of only permIttIng one
contInuous penod of parental leave IS consIstent WIth the provIsIOns of both the CollectIve
Agreement and the ESA Turmng first to the CollectIve Agreement, counsel argued that the
words utIlIzed by the partIes contemplate a sIngle parental leave of absence Counsel noted that
ArtIcle 24 7 provIdes that the Employer shall grant "a leave of absence" In accordance wIth the
ESA, and does not IndIcate that the Employer shall grant leaves of absence Counsel noted that
the references In ArtIcle 24 8 to when a parental leave may begIn and In ArtIcle 24 10 to when
such a leave ends are agaIn sIngular When referrIng to the nght to gIve notIce to change the end
ofa leave In ArtIcle 2410 counsel noted that there IS no provIsIOn for multIple notIces and
submItted that the partIes would have provIded for multIple notIces If they Intended that an
employee could take more than one parental leave wIthIn the allowable penod. Counsel
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submItted that by referrIng to a leave of absence the begInmng and end of a leave and the notIce
provIsIOns In the sIngular Illustrates that the partIes dId not contemplate that an employee could
take more than one penod of parental leave Counsel argued that the wordIng of the parental
leave provIsIOns do not present two lIngUIstIcally permISSIble meamngs
Counsel emphasIzed that ArtIcle 24 11 sets out two condItIOns for the receIpt of the top-
up payment. In addItIOn to the receIpt ofEI parental benefits, an employee must be entItled to
parental leave Counsel submItted that an employee who returns to work for the Employer after
a penod of parental leave IS no longer entItled to receIve the top-up payment dunng a subsequent
leave because there IS no entItlement under the ESA for an addItIOnal penod of parental leave
TurnIng to the ESA, counsel referred to the words In s 48( 1) and (2) and s 49(1) and (2),
and noted the utIlIzatIOn of the sIngular when a leave and a notIce are mentIOned, thereby
IllustratIng that only one leave IS contemplated. Counsel also submItted that the ESA, 2000
PolIcy and InterpretatIOn Manual ("the ESA Manual") can be used as an aid to InterpretatIOn.
The IntroductIOn In the ESA Manual IndIcates that the document "IS a pnmary reference source
of the polIcIes of the DIrector of Employment Standards respectIng the InterpretatIOn,
admInIstratIOn and enforcement of the ESA, 2000" It represents to the publIc the Employment
Standards Branch's VIew on how the parental leave proVIsIOns are to be admInIstered. In
commentIng on s 49(1) the ESA Manual provIdes as follows
18 6 1 End of Parental Leave, s. 49(1)
49(1) An employee's parental leave ends 35 weeks after It began, If the employee
also took pregnancy leave, and 37 weeks after It began, otherwIse
A parental leave wIll end 35 weeks after It began If the employee also took a
pregnancy leave, or 37 weeks after It began If the employee dId not take a
pregnancy leave, unless the employee provIdes notIce of an earlIer return date pursuant to
s 49(2) In other words, the employer must assume that an employee who has taken a
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parental leave wIll be gone for the full 35 or 37 weeks unless the employee gIves wntten
notIce to the contrary
ThIS provIsIOn IS sImIlar to the correspondIng provIsIOn (s 40(2)) of the former
Employment Standards Act (Under the former Act, the length of the parental leave was
18 weeks If the chIld was born and came Into the employee's custody care and control
before December 31 2000 the 35/37 week leave was avaIlable only to employees whose
chIld was born or came Into theIr custody care and control on or after December 31
2000 )
The length of parental leave was Increased In order to enable employees to take
advantage of the extended Employment Insurance parental benefits made avaIlable In
December 2000 It IS Important to note, however that there remaIn sIgmficant
dIfferences regardIng entItlements between the Employment Standards Act, 2000 and the
federal Employment Insurance Act For example, parents can take some paid work WIth
theIr employer WIthout lOSIng any EI parental benefits They can also Interrupt the penod
In whIch they receIve EI benefits and return to work, then begIn reCeIVIng benefits agaIn
at a later date However If an employee does eIther of those thIngs WIth respect to the
employer from whom they took the leave theIr parental leave wIll be consIdered to have
ended under the Employment Standards Act, 2000 (Employees wIll not be consIdered to
have ended theIr ESA, 2000 leave If they take work WIth an employer from whom they
dId not take the leave For example, an employee may take a parental leave from theIr
full-tIme Job WIth employer A and work part-tIme WIth employer B dunng theIr leave
WIthout lOSIng theIr entItlement to the ESA, 2000 parental leave from theIr full-tIme Job)
Once an employee begIns a parental leave, they have the nght to take the full
35 or 37 weeks For example, a bIrth father whose chIld dIes five weeks Into hIS
parental leave has the nght to take the remaInIng 32 weeks ofleave Ifhe WIshes
To support the proposItIOn that the ESA Manual can and should be used as an aid
to Interpret the parental leave proVIsIOns, counsel relIed on Re Olympia York Development Ltd
and leT U Loc 6 (1994) 43 L AC (4th) 71 (Kates) The Issue In that case concerns how
overtIme hours worked should be credIted In the gnevor's overtIme bank. ConcludIng that the
InterpretatIve manual was not bIndIng but could be used as an aid to InterpretatIOn, arbItrator
Kates found the umon' s InterpretatIOn of the relevant collectIve agreement proVIsIOn more
reasonable and that "Moreover that InterpretatIve approach WIth respect to the contentIOUS term
contaIned In art. 9 11 of the collectIve agreement IS supported by the publIc polIcy consIderatIOns
contaIned In the InterpretatIve gUIdelInes descnbed In the InterpretatIOn manual Issued by the
Employment Standards Branch and whIch IS Intended for umform applIcatIOn save to the extent
the collectIve agreement expressly Intends the contrary "
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Counsel also referred to certaIn parts of the Mimstry of Labour's websIte whIch
comments on pregnancy/parental leave In a Fact Sheet. The Fact Sheet begIns by notIng that It IS
for InfOrmatIOn and convemence only and that It IS not a legal document. Counsel submItted that
the advIce In the Fact Sheet IS consIstent WIth the Employer's InterpretatIOn of the pregnancy/
parental leave provIsIOns The folloWIng questIOn and answers are set out In the Fact Sheet
Does pregnancy leave have to be taken all at one time?
Yes Once an employee has started her Pregnancy leave, she must take It
all at once and cannot splIt It up
Does Parental leave have to be taken all at one time?
Yes Once an employee has started Parental leave, he or she must take It all at one tIme
and can't splIt It up An employee can't use up part of the leave, return to work for the
employer from whIch he or she took the leave and then go back on Parental leave for the
unused portIOn.
Although the federal Employment Insurance program allows employees to earn a lImIted
amount of wages wIthout havIng theIr parental benefits reduced, an employee who goes
back to work for the employer from whom he or she took the leave, even If It IS only for a
few hours a week, wIll gIve up the rest of hIS or her leave
Counsel noted that there are other ways In whIch the ESA and the EIA do not mIrror each
other beSIdes the area that dIvIdes the partIes In thIS dIspute She noted that an employee may
begIn a parental leave under the ESA no later than 52 weeks after the bIrth, but an employee who
begIns the leave In the 51st week wIll collect lIttle In the way ofEI parental benefits because the
penod for paYIng benefits under the EIA ends 52 weeks after the week In whIch the chIld IS born.
She also referred to the provISIOn In the EIA whIch permIts the extensIOn of the payment penod
If a chIld IS hospItalIzed and that the ESA does not contaIn a provISIOn for extendIng the
maXImum allowable parental leave penod.
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Counsel submItted that the ESA parental leave provIsIOns reflect a number of polIcy
consIderatIOns She noted that the purpose of these provIsIOns IS to permIt parents to take tIme
off work to spend tIme WIth theIr young chIldren wIthout lOSIng theIr Job Counsel submItted
that the reqUIrement for one contInUOUS leave recogmzes the Interests of employers She argued
that such a reqUIrement IS Intended to mImmIze admInIstratIve dIfficultIes and the dIsruptIOn and
uncertaInty that would be created If an employee were entItled to take multIple parental leaves
totallIng the maXImum 37 weeks Counsel argued that a reVIew of the parental leave provIsIOns
as a whole Illustrates a scheme whereby an employee IS entItled to take only one contInUOUS
leave of absence
The essence of the Umon' s posItIOn IS that there IS nothIng In the CollectIve Agreement
or the ESA whIch prevents an employee from takIng more than one parental leave, recogmZIng
that the total number of weeks cannot exceed 37 weeks In ItS VIew an employee IS entItled to
an addItIOnal parental leave and the top up payment, as long as the condItIOns for reCeIVIng thIS
payment have been met. Counsel for the Umon argues that the Employer's InterpretatIOn of the
relevant provIsIOns IS too restnctIve and that the Employer IS readIng words Into the CollectIve
Agreement and the ESA whIch are sImply not present. Counsel asserts that the Umon's
InterpretatIOn of the ESA IS consIstent WIth pnncIples artIculated by the Supreme Court of
Canada In decIsIOns InvolvIng the ESA and the EIA
Counsel submIts that there IS no partIcular magIc In the use of the words "a leave of
absence" In the CollectIve Agreement and In the ESA Counsel argued that If the partIes and the
LegIslature Intended that there be a sIngle leave or one contInUOUS leave they would have used
dIfferent language to express such an IntentIOn and the absence of such language suggests that
they had no such IntentIOn. In counsel's submIsSIOn, the use of the words "a leave of absence" IS
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not InCOnsIstent WIth the notIOn that an employee can take a parental leave for a number of
weeks, return to work for the Employer and then take another parental leave Counsel submItted
that the words "a leave" could mean each leave, that the oblIgatIOn to gIve two weeks notIce
before the leave IS to begIn can be gIven before takIng an addItIOnal parental leave and that the
words "an employee may begIn parental leave In s 48(2) of the ESA suggests that an employee
can take more than one parental leave
Counsel referred to ArtIcle 8 3 of the CollectIve Agreement whIch deals wIth leave of
absence for ASSOCIatIOn actIVItIes and s 50(1) of the ESA, the emergency leave provISIOn, to
Illustrate examples of where the words "a leave of absence" are used In other provISIOns and
where the IntentIOn IS to refer to multIple leaves of absence Counsel argued that there IS no
basIs for concludIng that the use of the same words In the parental leave provISIOns should be
Interpreted dIfferently and In the restnctIve manner suggested by the Employer
In InterpretIng the ESA, counsel argued that It IS Important to take Into account the
relatIOnshIp between the parental leave provISIOns In the ESA and the EIA Counsel noted that
the proVInCIal statute entItles employees to take tIme off from work wIth Job protectIOn, whIle the
federal statute provIdes for the payment of benefits whIle an employee IS off work on parental
leave Counsel also noted that an employee can contInue to receIve EI parental benefits for
addItIOnal tIme off work, even after they enJoyed an ImtIalleave and returned to work for theIr
employer Counsel submItted that the parental leave provISIOns In both statutes are Intended to
be complementary and that an InterpretatIOn of the ESA whIch dIsentItles an employee to a
parental leave whIle the employee can be off work reCeIVIng EI parental benefits does not make
sense Counsel referred to a sectIOn of Hansard to Illustrate that the LegIslature Intended that the
parental leave provISIOns In the ESA complement the relevant EIA provISIOns In commentIng In
15
Hansard Issue L121B on BIll 147 an Act to reVIse the law related to employment standards, Mr
Joseph Tascona (Bame-SImcoe-Bradford) spoke on behalf of the Government as follows
Parental leave IS ObvIOusly very fundamentally Important for people who desIre to raise a
famIly or have a famIly They need that balance to be able to deal wIth the sItuatIOn. The
federal government has Increased the entItlement penod that you can collect employment
Insurance benefits up to 52 weeks It's the Employment Standards Act that has to
complement that. It's the Employment Standards Act that allows for the tIme to be taken
off and not lose your J ob and to make sure that penod of tIme IS set out to match the
federal employment Insurance benefits OtherwIse It doesn't make a lot of sense to be
provIdIng federal employment Insurance benefits for parental leave for a certaIn penod of
tIme If the proVInce doesn't match It to make sure there's J ob protectIOn for that entIre
penod.
Counsel submItted that, In order to complement the federal scheme for compensatIng
employees on parental leave, the LegIslature Intended to permIt employees to splIt up theIr
parental leave and that the language In the ESA reflects thIS IntentIOn. Counsel argued that any
dIfferences between the EIA and the ESA are clearly set out In each statute, but there IS no
IndIcatIOn In the ESA that employees cannot splIt up theIr parental leave
WhIle acknowledgIng that an InterpretatIOn manual could be used as an aid to
InterpretatIOn, counsel submItted that I was not bound by the ESA Manual and that, In thIS
Instance, the reference In the ESA Manual to the Issue In dIspute should be gIven no weIght.
Counsel argued that the ESA Manual SImply asserts that an employee cannot splIt up parental
leave wIthout proVIdIng a basIs for thIS assertIOn and wIthout proVIdIng a polIcy context to
support the assertIOn. Counsel submItted that the absence of any polIcy JustIficatIOn for the
assertIOn In the ESA Manual dIstIngUIshes thIS case from Re Olympia York Development Ltd and
leT U Loc 6 supra, where arbItrator Kates had the benefit of the polIcy conSIderatIOns set out
In the ESA Manual wIth respect to the Issue there In dIspute Counsel also submItted that the
Mimstry of Labour's Fact Sheet on Pregnancy Leave & Parental Leave, for sImIlar reasons, and
16
because of the nature of the document, should not be used In InterpretIng the parental leave
provIsIOns In the ESA
Counsel also submItted that It would be Inappropnate to take Into account any dIsruptIOn
that mIght occur to employers Counsel argued that the parental leave provIsIOns do not suggest
that the pnncIple of aVOIdIng dIsruptIOn to an employer's busIness IS a relevant factor other than
by provIdIng a notIce reqUIrement. In counsel's submIssIOn, the dIsruptIOn Issue IS addressed by
requmng an employee to gIve an employer wntten notIce at least two weeks before the leave IS
to begIn, whether It IS an ImtIalleave or a subsequent parental leave
Counsel submItted that It IS necessary when InterpretIng the relevant provIsIOns of the
ESA to take Into account the purpose of parental leave and to consIder the provIsIOns as a whole
Counsel submItted that It IS InCOnsIstent WIth the ObVIOUS purpose of parental leave to Interpret
the ESA In a way whIch demes an employee entItlement to an addItIOnal parental leave In
counsel's VIew the Employer's posItIOn IS not conSIstent
WIth the purpose of the parental leave provIsIOns
Counsel referred to a number of Supreme Court of Canada decIsIOns In support of hIS
submIssIOn that In InterpretIng employment related statutes such as the EIA and the ESA the
Court, where appropnate, prefers an InterpretatIOn whIch favours the Interests of employees
Counsel referred me to certaIn passages In the decIsIOns, wIthout fOCUSIng on the specIfic facts In
each case I wIll take the same approach In bnefly reVIeWIng four of the decIsIOns
In the first three cases, the Court IS InterpretIng certaIn provISIOns In the former
Unemployment Insurance Act, 1971 ('the UIA") In Canada (Attorney General) v Abrahams
17
[1983] 1 S C.R. 2, the Issue was whether a claimant was dIsentItled to benefits under the UIA, by
VIrtue of s 44( 1 ) In findIng In favour of the claimant, Wilson J wntIng for the Court,
comments as follows
SInce the overall purpose of the Act IS to make benefits avaIlable to the unemployed, I
would prefer a lIberal InterpretatIOn of the re-entItlement provIsIOns I thInk any doubt
anSIng from the dIfficultIes of the language should be resolved In favour of the
claimant
In Hills v Canada (Attorney General) [1988] 1 S C.R. 513 the Issue was whether the
claimant who lost hIS employment as a result of a work stoppage could prove that he was not
"finanCIng" the labour dIspute wIthIn the meamng of s 44(2)(a) In allOWIng the appeal,
L'Heureux-Dube J wntIng for the maJonty wrote as follows
96 WhIle sectIOn 44 may be open to a broad InterpretatIOn of "financIng" In my VIew
the purpose of the sectIOn (to dIsentItle stnkers from benefits) as well as the purpose of
the Act as a whole (to proVIde benefits to Involuntanly unemployed persons) dIctate that
a narrow InterpretatIOn be gIven to the dIsentItlement provIsIOns of that sectIOn. Any
doubt, as Wilson J pOInted out In Abrahams supra, should be resolved In favour of the
claimant, partIcularly In the context descnbed above
In Canada (Canada Employment and Immigration Commission) v Gagnon [1988]
2 S C.R. 29 the Issue was whether a claimant IS entItled to an extenSIOn of hIS benefit penod
under s 20(7)(b) of the UIA In allOWIng the appeal, L'heureux-Dube J wntIng for the Court,
wrote as follows
44 In bnef, both the wordIng and the context, as well as the IntentIOn that emerges from
the Act, support the appellant's InterpretatIOn.
45 That IS not to say that the proVISIOns of the Act are a model of clanty TryIng to
reconcIle them reqUIres an uncommon degree of dextenty WIth the result that In
borderlIne cases such as the one at bar where two InterpretatIOns are pOSSIble takIng Into
account that the purpose of the Act IS to compensate workers who are Involuntanly
unemployed, the worker must be gIven the benefit of the doubt (Abrahams V Attorney
General of Canada, supra)
18
The next decIsIOn Involves InterpretIng the ESA At Issue In Rizzo & Rizzo Shoes Ltd
[1998] 1 S C.R. 27 was whether the termInatIOn of employment caused by the bankruptcy of an
employer gave nse to a claim provable In bankruptcy for termInatIOn pay and severance pay
under the ESA Access to the benefits at Issue under the ESA turns on the questIOn of whether
employment was termInated "by an employer" NotIng the plaIn language In the relevant
statutory provIsIOns, the Court of Appeal held that employees termInated as a result of a
bankruptcy were termInated by operatIOn of law and not "by an employer" In allowIng the
appeal, IacobucCI J wntIng for the Court,
commented as follows
22 I also rely on s 10 of the InterpretatIOn Act, R.S 0 1980 c.219 whIch
proVIdes that every Act "shall be deemed to be remedIal" and dIrects that every Act shall
"receIve such fair large and lIberal constructIOn and InterpretatIOn as wIll best ensure the
attaInment of the obJect of the Act accordIng to ItS true Intent, meamng and spmt"
23 Although the Court of Appeal looked to the plaIn meamng of the speCIfic proVISIOns
In questIOn In the present case, WIth respect, I belIeve that the court dId not pay suffiCIent
attentIOn to the scheme of the ESA, ItS obJect or the IntentIOn of the legIslature nor was
the context of the words In Issue appropnately recogmzed
36 Finally WIth regard to the scheme of the legIslatIOn, SInce the ESA IS a mechamsm for
proVIdIng mImmum benefits and standards to protect the Interests of employees, It can be
charactenzed as benefits-confernng legIslatIOn. As such, accordIng to several deCISIOns
of thIS Court, It ought to be Interpreted In a broad and generous manner Any doubt
anSIng from dIfficultIes oflanguage should be resolved In favour of the claimant (see,
e g. Abrahams v Attorney General of Canada, [1983] 1 S C.R. 2, at p 10 Hills v
Canada (Attorney General) [1988] 1 S C.R. 513 at p 537) It seems to me that, by
lImItIng ItS analYSIS to the plaIn meamng of ss 40 and 40a of the ESA, the Court of
Appeal adopted an overly restnctIve approach that IS InCOnSIstent WIth the scheme of the
Act.
Counsel submItted that the language In the relevant proVISIOns, both In the CollectIve
Agreement and In the ESA IS clear and conSIstent WIth the InterpretatIOn advanced by the Umon.
However If I found that the language IS capable of two InterpretatIOns or ambIguous, counsel
submItted that the applIcatIOn of the pnncIples artIculated by the Supreme Court of Canada In the
19
foregoIng decIsIOns should result In an InterpretatIOn of the parental leave provIsIOns In the ESA
whIch allows employees to take more than one leave of absence
The CollectIve Agreement specIfically provIdes In ArtIcle 24 7 that the Employer shall
grant a parental leave of absence wIthout pay In accordance wIth Part XIV of the ESA The
provIsIOns In the CollectIve Agreement whIch provIde employees wIth addItIOnal benefits whIle
on parental leave, such as the top-up provIsIOn, are avaIlable to employees as long as they are
entItled to parental leave Therefore as both counsel recogmzed, a resolutIOn of thIS dIspute
reqUIres me to Interpret the parental leave provIsIOns In the ESA Although the focus has been on
parental leave, I note that that the relevant words In s 24.2 of the ESA, the pregnancy leave
provIsIOn, are vIrtually IdentIcal to the words used In the parental leave provIsIOns Therefore,
the InterpretatIOn one gIves to the parental leave provIsIOns In the ESA would undoubtedly have
an Impact on the pregnancy leave provIsIOns as well
As preVIOusly noted, I was referred to the ESA Manual, the Fact Sheet and the extract
from Hansard reproduced above I am not prepared to gIve any sIgmficant weIght to these
sources I agree wIth counsel for the Umon that the ESA Manual sImply asserts that an employee
cannot splIt up parental leave, wIthout provIdIng any explanatIOn or any polIcy basIs for the
assertIOn and therefore IS not partIcularly helpful The Fact Sheet IS sImIlarly of lIttle assIstance
In Rizzo & Rizzo Shoes Ltd supra, the Court, In commentIng on the lImIted role Hansard can
play In the InterpretatIOn of legIslatIOn, referred to the folloWIng comment In R v Morgentaler
[1993] 3 S C.R. 463 at p 484 " ProVIded that the court remaInS mIndful of the lImIted
relIabIlIty and weIght of Hansard eVIdence, It should be admItted as relevant to both the
background and purpose oflegIslatIOn." The extract from Hansard does bnefly touch on the
background and the purpose of the parental leave amendments, and to thIS extent IS somewhat
20
useful However the general reference to the complementary nature of the ESA and the EIA
whIch undoubtedly eXIsts to a degree, IS not partIcularly helpful wIth respect to the specIfic Issue
whIch IS In dIspute between the partIes
In InterpretIng the parental leave provIsIOns In the ESA, It IS Important to consIder
the purpose of these provIsIOns and the relevant words contaIned thereIn In the context of the
parental leave provIsIOns as a whole HavIng regard to the InterpretIve approach of the Supreme
Court of Canada as demonstrated by the references set out above, It IS to be noted that parental
leave provIdes a dIfferent context from those addressed In the Court decIsIOns Parental leave IS
a benefit whIch an employee IS not compelled to take It IS avaIlable to an employee on a
voluntanly basIs If an employee elects to take parental leave, he or she can take the full
entItlement of 37 weeks or can take less than hIS or her full entItlement. The comments of the
Court In the EIA cases are made In the context of a statute whIch IS desIgned to compensate
workers who are Involuntanly unemployed. In Rizzo & Rizzo Shoes Ltd supra, the Court was
dealIng wIth the applIcatIOn of the ESA In CIrcumstances where employees had been termInated
by a bankruptcy Although the parental leave provISIOns provIde a dIfferent and umque context,
the comments of the Court, partIcularly In Rizzo & Rizzo Shoes Ltd supra, are nonetheless stIll
applIcable to the CIrcumstances before me The ESA IS benefits-confernng legIslatIOn and should
not be Interpreted In restnctIve manner Rather the ESA should be Interpreted In a broad and
generous manner conSIstent WIth the dIrectIOn contaIned In s 10 of the Interpretation Act
After consIdenng the relevant parental leave provISIOns In the ESA In lIght of the
submISSIOns of counsel and after applYIng the InterpretatIve approach referred to above, It IS my
conclUSIOn that the LegIslature Intended to proVIde employees wIth the opportumty to take one
contInUOUS parental leave of absence folloWIng a bIrth or an adoptIOn
21
As counsel for the Employer noted, the words used In s 48 and s 49 of the ESA are In the
sIngular whIch suggests an IntentIOn to provIde for a sIngle leave of absence For example, s
48( 1) refers to "a leave of absence" s 48(2) uses the words "may begIn a parental leave" and the
notIce reqUIrement In s 48(4) reqUIres that an employee gIve at least two weeks wntten notIce
before the day "the leave" IS to begIn. S 49(1) provIdes that "an employee's parental leave
ends" eIther 35 or 37 weeks after It began. The wordIng of the relevant provISIOns does not
dIsclose an IntentIOn to proVIde more than one leave of absence If the LegIslature had Intended
to proVIde for multIple parental leaves, such an IntentIOn could have been easIly expressed by
USIng dIfferent language SImIlarly If the words "a leave" In s 48(1) were Intended to mean
"each leave" as the Umon argued, the draftsperson could easIly have used language to proVIde
that more than one leave could be taken. Although the words In s 48 and s 49 of the ESA are
sIgmficant In that they contemplate a sIngle leave I agree wIth the Umon that the InqUIry cannot
end there and must also conSIder the words wIthIn the parental leave provISIOns as whole
An eXamInatIOn of the parental leave provISIOns as a whole suggests the creatIOn of a
well-defined parental leave scheme What IS also notIceable IS the absence of the type of
provISIOns one would expect If employees were entItled to take more than one parental leave
after the bIrth of a chIld or an adoptIOn. S 48(1) proVIdes for "a leave of absence" and s 48(4)
reqUIres that an employee gIve two weeks wntten notIce before the day the leave IS to begIn. S
48(5) permIts an employee, upon 2 weeks wntten notIce, to change the start of a leave to an
earlIer or a later day S 49 addresses the endIng of a parental leave, wIth s 49(1) proVIdIng that
"an employee's parental leave ends" 35 or 37 weeks "after It began" S 49(2) permIts an
employee to end the parental leave earlIer than the 35 or 37 weeks, upon 4 weeks wntten notIce
22
S 49(3) permIts an employee who has provIded a notIce to end the parental leave, to end the
leave on an earlIer or a later day provIdIng the employee gIves 4 weeks wntten notIce
The scheme created by the foregoIng provIsIOns has a number of tellIng features It IS
assumed that an employee takIng parental leave wIll take the full 37 weeks, unless the employee
gIves notIce of an earlIer end date Such an assumptIOn IS consIstent WIth the notIOn of a sIngle
parental leave of absence ProvIdIng that the leave ends 37 weeks after It began, rather than
sImply provIdIng that an employee IS entItled to 37 weeks of parental leave, suggests that
parental leave IS to be for a sIngle contInUOUS penod. A provISIOn whIch permIts an employee,
upon 4 weeks wntten notIce, to change the end day of the leave to a later day wIth the potentIal
result that an employee wIll enJ oy 37 weeks of parental leave, appears agaIn to be consIstent WIth
an IntentIOn to provIde only a sIngle leave of absence It seems to me that It would be
unnecessary to have such a provISIOn If an employee was entItled to take more than one parental
leave If the Umon' s posItIOn IS correct, an employee could gIve two weeks wntten notIce and
take a second parental leave, whether the employee returned to work or not, rather than
extendIng the ImtIalleave In fact, entItlement to a second parental leave could create a conflIct
WIth the proVISIOn whIch permIts extendIng the end day ThIS could anse In a sItuatIOn where an
employee, two weeks from the end day WIshes to extend the end day of a parental leave, but IS
unable to due so because the four weeks wntten notIce cannot be gIven. If entItlement to a
second parental leave WIth two weeks notIce was avaIlable the employee could proVIde
suffiCIent notIce to take a second parental leave to begIn ImmedIately upon the completIOn of the
first one ThIS result would be InCOnSIstent WIth the reqUIrement to gIve at least 4 weeks notIce
to change the end day of a leave In lIght of the above observatIOns, whIch clearly suggest an
IntentIOn to proVIde for a SIngle contInUOUS parental leave, one would expect explICIt language to
23
support an IntentIOn to provIde for multIple parental leaves Language eVIdencIng such an
IntentIOn IS sImply not present.
The Umon pOInts to the words "a leave of absence" In S 50(3) of the ESA In support of ItS
posItIOn. S 50 provIdes that an employee IS entItled to an emergency leave of absence upon any
one of a number of tnggenng events An employee under thIS provIsIOn can take a total of 10
days' leave each year When one consIders S 50 as a whole, It IS qUIte clear from the context
that an employee IS entItled to more than one leave under thIS provISIOn. The context In S 50
serves to hIghlIght the dIfferent context that eXIsts for the parental leave provISIOns The
eXIstence of one tnggenng event, the bIrth of a chIld or an adoptIOn, and the opportumty to take a
maXImum number of weeks ofleave whIch must commence wIthIn a speCIfic penod, suggests
also that a sIngle leave IS contemplated by the parental leave provISIOns
The Umon relIes on that fact that the ESA IS Intended to complement the EIA and submIts
that the ESA should be Interpreted In a way whIch favours splIttIng up a parental leave because
an employee IS entItled to receIve EI parental benefits even If weeks of unemployment are
Interrupted by a return to work. I agree wIth the Employer's submIsSIOn that the fact the parental
leave provISIOns In the ESA and the parental benefits provISIOns In the EIA are not completely
complImentary takes some force away from the Umon' s submIsSIOn. One sIgmficant dIfference
between the two statutes concerns when an employee can start a parental leave under the ESA
and when EI parental benefits are no longer payable under the EIA EI parental benefits are
payable only wIthIn a penod of 52 weeks from the bIrth, yet an employee can commence a
parental leave Just before the 52nd week after the bIrth. An employee who commences a parental
leave In the 51 st week after a bIrth wIll only receIve EI parental benefits for the one week.
Although thIS scenano would not lIkely occur In practIce thIS potentIal sItuatIOn demonstrates In
24
a fairly dramatIc way that there can be a dIsconnect between takIng a parental leave and
reCeIVIng EI parental benefits Conversely Just because an employee IS In receIpt ofEI parental
benefits does not mean, by Itself, that the employee IS entItled to parental leave If It was
Intended that entItlement to a parental leave IS only dependent on an employee reCeIVIng EI
parental benefits, such an IntentIOn could have been easIly and clearly expressed.
The Umon argues that InterpretIng the parental leave provIsIOns In a way whIch demes
employees entItlement to an addItIOnal parental leave IS InCOnsIstent WIth the purpose of these
provIsIOns It also argues that It would be Inappropnate to take Into account the dIsruptIOn
multIple leaves of absence would cause the Employer when InterpretIng the parental leave
provIsIOns, gIven that thIS Issue has been addressed by the reqUIrement to gIve wntten notIce I
dIsagree wIth these submISSIOns
The pnmary purpose of the parental leave provIsIOns IS to proVIde an employee wIth the
opportumty to be away from work after the bIrth of a chIld or an adoptIOn, wIthout nskIng the
loss of one's Job However It IS clear from the provIsIOns In theIr entIrety that an effort has been
made to balance thIS employee benefit wIth an employer's Interest In aVOIdIng undue dIsruptIOn
to ItS operatIOns If the Umon' s posItIOn represented the preferred InterpretatIOn, an employee
could gIve the reqUIred notIce and alternate between a week of parental leave and a week at work
for the Employer for a number of months If It were possIble to take less than a full week of
parental leave, an employee could take every Fnday and Monday off for a penod of tIme whIle
workIng the rest of the week. SplIttIng up parental leave In thIS manner would have the potentIal
to be qUIte dIsruptIve for an employer even when the reqUIred notIce has been gIven, and there IS
nothIng In the ESA parental leave provISIOns whIch remotely contemplates such a result. I agree
wIth the Employer's submISSIOn that the desIgn of the parental leave provISIOns to proVIde for a
25
sIngle leave of absence IS Intended In part to aVOId the dIsruptIOn that could be created If
employees were permItted to splIt up parental leave In my VIew a reqUIrement that an
employee can only take one leave has the effect of ensunng that employees wIll take a leave for
as long as possIble, thereby ensunng that the purpose of the provIsIOn wIll be served.
I am satIsfied that the words In the parental leave provIsIOns In the ESA are not
capable of two meamngs when consIdered In lIght of theIr purpose and the context of the
provIsIOns as a whole The ESA provIdes for a sIngle parental leave of absence, whatever ItS
duratIOn. Once an employee returns to work for the Employer at the end of a parental leave, the
entItlement to parental leave has been exhausted, even If the employee dId not take the full 37
weeks of parental leave SImIlarly It follows that the CollectIve Agreement also contemplates
that an employee IS entItled to take one contInUOUS parental leave of absence An employee IS
not entItled to a second parental leave dunng whIch the top-up payment IS avaIlable
Dated at Toronto thIS 29th day of March, 2005