HomeMy WebLinkAbout2005-2261.McNaughton.06-02-01 Decision
Crown Employees Commission de Nj
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# 2005-2261
UNION# OLB538/05
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontano LIqUor Boards Employees' Umon
(McNaughton) Union
- and -
The Crown In RIght of Ontano
(LIqUor Control Board of Ontano) Employer
BEFORE Nimal V DIssanayake Vice-Chair
FOR THE UNION Ernest A. SchIrm
Koskie Minsky LLP
BarrIsters & SOlICItorS
FOR THE EMPLOYER AlIson E Renton
Counsel
LIqUor Control Board of Ontano
HEARING January 18 2006
2
DeCISIon
Thls declslon pertalns to a dlscharge grlevance dated
October 4 , 2005 flIed by Ms Mellnda McNaughton The case
was argued on the basls of an Agreed Statement of Fact and
no Vlva voce eVldence was called The agreed facts are as
follows
AGREED STATE:MENT OF FACTS
The Employer and the Unlon (herelnafter "The Partles")
agree that the followlng agreed statement of facts lS
belng entered lnto thls matter wlthout pre]udlce and
precedent to any other matter between the Partles and
may be supplemented by elther Party by viva voce
eVldence
1 The Grlevor commenced employment as a casual
warehouse worker at the London Retall SerVlce
Centre In 1999 On Aprll 25, 2005 she was promoted
to a full tlme warehouse worker 3 at the London
Retall SerVlce Centre
2 Effectlve March 25, 2003, the Grlevor was
termlnated from her posltlon A Grlevance was
flIed and the Grlevor clalmed that she had an
alcohol addlctlon whlch was accepted by the
Employer Mlnutes of Settlement were entered lnto
dated Aprll 11, 2003 (herelnafter "the 2003
Mlnutes") whlch set out varlOUS treatment
requlrements by whlch the Grlevor had to follow A
copy of the 2003 Mlnutes are appended hereto as
Appendlx "A"
-
3
3 Pursuant to the 2003 Mlnutes, the Grlevor was
relnstated
4 By letter dated September 12, 2003, the Grlevor was
termlnated from her posltlon A Grlevance was flIed
and was referred to the GSB as the subJect matter
of GSB # 2071/03 Agaln, the Grlevor clalmed that
she had an alcohol addlctlon whlch was accepted by
the employer Mlnutes of Settlement were entered
lnto dated February/March 2004 (herelnafter "the
2004 Mlnutes") whlch set out varlOUS requlrements,
and addlctlon treatments for the Grlevor to follow
and the Grlevor was relnstated The Grlevor was
represented by unlon counsel durlng thls
proceedlng A copy of the 2004 Mlnutes are
appended hereto as Appendlx "B"
-
5 On Tuesday, September 13, 2005, the Grlevor was
absent from the workplace She returned to work
September 14, 2005 She dld not brlng a doctor's
note to substantlate her absence wlthln three (3)
calendar days as requlred by paragraph 10 of the
2004 Mlnutes The Grlevor otherwlse malntalned an
attendance rate wlthln the parameters set out In
paragraph 10 of the 2004 Mlnutes
6 The Grlevor was lssued a letter dated September 20,
2005 for not brlnglng In a doctor's note wlthln
three (3) calendar days and a meetlng was scheduled
for September 28, 2005 A copy of the September
20, 2005 letter lS appended hereto as Appendlx "c"
-
7 The grlevor attended the September 28, 2005 meetlng
along wlth her unlon representatlves, Steve
Saysell, Joe Hollyman and Jlm McNelly Robert Cote
and Mark Wagner attended the meetlng as the
Employer's representatlves At the meetlng, and
for the flrst t lme , the Grlevor provlded a doctor's
4
note dated September 13, 2005 that lS appended
hereto as Appendlx "D" The Grlevor stated In the
meetlng that on September 13, 2005 she called her
doctor's offlce for an appolntment but was not able
to obtaln one The Grlevor dld not obtaln an
appolntment wlth her doctor untll September 23,
2005 Durlng thls appolntment, she asked her
doctor to back date the note to September 13, 2005,
whlch the Grlevor dlsclosed to the Employer durlng
the September 28 meetlng At the meetlng, the
Grlevor stated that she knew and understood the
terms of the 2004 Mlnutes At the meetlng, the
Grlevor dld not relate her absence or her fallure
to brlng In a doctor's note due to an alcohol
addlctlon There lS no lssue wlth respect to
whether or not the Grlevor was actually III on the
day In questlon
8 By letter dated October 3, 2005, the Grlevor was
termlnated A copy of thls termlnatlon letter lS
appended hereto as Appendlx "E"
-
8a A stage 3 grlevance, dated October 4 , 2005 was
flIed A copy of the grlevance lS appended hereto
as Appendlx "F"
-
9 Paragraph 11 of the 2004 Mlnutes state
The Parties agree tha t failure to meet any of the
requirements of the agreement for the two (2) year
period following the Grievor's reinsta temen t shall
result in the Grievor's termination without the
right to redress through the grievance and/or
arbi tra tion process except to establish the
veracity of the facts upon which the Employer
relied
10 Paragraph 12 of the 2004 Mlnutes states
5
The Parties agree that an arbitrator's jurisdiction
shall be limited solely to determining the facts
upon whi ch the Employer relied, as set out in
paragraph 11 above, and the Parties agree that an
arbitrator shall not have the jurisdiction to
substitute the penalty of discharge
11 Artlcle 12 4 of the Collectlve Agreement states
After five (5) days absence caused by sickness or
injury, no 1 ea ve with pay shall be allowed unless a
certifica te of a legally qualified medical
practi tioner is forwarded to the Employer
certifying as to the nature of the sickness and
tha t the employee is unable to attend to his/her
official duties Notwi thstanding this provision,
the Employer may require an employee to submit the
certifica te required hereunder in respect of a
period of absence of less than five (5) days
12 The Partles put to the Arbltrator the followlng
questlon
a) Should the Grlevor's termlnatlon be upheld for
breachlng the 2004 Mlnutes?
13 The Unlon puts to the Arbltrator the followlng
questlons
Do paras 10, 11, 12 of the 2004 Mlnutes vlolate
the HRC?
If yes, are the 2004 Mlnutes vOld and/or
unenforceable to the extent they vlolate the HRC?
ALL OF WHICH IS SUBMITTED, THIS 18TH DAY OF JANUARY,
2006 In London, OntarlO
(Attachments oml tted)
6
The 2004 Mlnutes of Settlement under whlch the grlevor
had been relnstated, referred to by the partles as "the
last chance agreement" (herelnafter "LeA") , lncluded
paragraphs 11 and 12 set out In the agreed facts as well as
paragraph 10 whlch reads
10 The Grlevor agreed that upon her return to actlve
work, she shall malntaln an attendance rate,
excluslve of vacatlon, pre-approved absences, or
serlOUS lllness or serlOUS accldent, as follows
For the flrst SlX ( 6) months followlng
relnstatement, she shall mlSS no more than three
(3 ) shlfts For the followlng SlX ( 6) months, she
shall mlSS no more than flve (5) shlfts For the
year followlng the two (2 ) SlX ( 6) month perlods,
she shall mlSS no more than ten (10 ) shlfts The
-
Grlevor shall provlde documentatlon substantlatlng
such absence wlthln three (3) calendar days upon
her return to work Further, the Grlevor agrees
that, wlthout exceptlon, she shall report all
absences and late arrlvals In a tlmely manner, and
speclflcally not less than flfteen (15) mlnutes
prlor to the beglnnlng of her scheduled shlft,
except In sltuatlons of serlOUS lllness and In
sltuatlons as serlOUS accldent requlrlng
hospltallzatlon The Grlevor shall call and speak
In person wlth a supervlsor and In the event she
has left a VOlce mall message before the
commencement of her shlft, she shall call agaln and
speak In person wlth a supervlsor to conflrm the
VOlce mall message
(Emphasls added)
The agreed facts establlsh that the grlevor was absent
on Tuesday September 13, 2005 Documentatlon
substantlatlng that absence was provlded to the employer
7
only on September 28, 2005 Thus, the unlon concedes that
the grlevor vlolated that requlrement In the LCA
The partles agree that the grlevor suffered from an
alcohol addlctlon, and that as such she was subJect to a
"dlsablllty" wlthln the meanlng of s 5 (1) of the Ontarlo
Human Rlghts Code, whlch In part reads
5 (1) Every person has a rlght to equal treatment wlth
respect to employment wlthout dlscrlmlnatlon because of
dlsablllty
The unlon's prlmary argument lS based on s 5 It
submlts that paragraph 10 of the LCA whlch requlres the
grlevor to provlde documentatlon substantlatlng absences
wlthln 3 days upon returnlng to work as well as paragraphs
11 and 12 whlch prescrlbe automatlc termlnatlon and llmlt
an arbltrator's Jurlsdlctlon do not apply to other
bargalnlng unlt employees The only reason the grlevor was
subJected to those extra-ordlnary terms lS because of her
dlsablllty, l e her alcohol addlctlon Therefore, the
argument goes, those terms are dlscrlmlnatory on the
grounds of dlsablllty contrary to s 5 of the Human Rlghts
Code, and are of no force and effect
8
Unlon counsel acknowledged that the grlevor's absence
on the day In questlon or her fallure to provlde medlcal
documentatlon wlthln 3 days for that absence was not
related to her alcohol addlctlon However, he submltted
that that was not the relevant lssue The crltlcal fact
was that the grlevor would not have been subJect to the
requlrement In the flrst place, but for her past hlstory of
absences due to her dlsablllty
Employer counsel remlnded the Board of the well
establlshed prlnclple that partles should be held to the
undertaklngs made In grlevance settlements She stressed
that good labour relatlons pollcy requlres that the
grlevance settlements be strlctly enforced Re Braybrooke
1437/01 (Dlssanayake) She submltted that the grlevor had
reaped the beneflts of the 2004 Mlnutes of Settlement,
lncludlng belng relnstated In her Job, and that she was now
seeklng to be relleved of the obllgatlons she had
undertaken In return Unlon counsel dld not dlspute the
general prlnclple that grlevance settlements must be
strlctly enforced However, he submltted that any term of
settlement that contravened the Human Rlghts Code lS vOld
and unenforceable An arbltrator ought not, and lS not
9
requlred by any legal prlnclple, to enforce or uphold a
term In a settlement whlch contravenes the Code
I agree wlth the general prlnclple espoused by the
employer, as well as the exceptlon relled upon by the
unlon The case law clearly supports that posltlon For
example, In Re Labatt Brewerles Ontarlo, (2002 ) 107 LAC
(4 th) 126 (Barrett) at p 140, the arbltrator states, "I am
strongly In favour of upholdlng last chance agreements
unless they are In vlolatlon of the Human Rlghts Code " A
well reasoned statement In that regard lS contalned In Re
-
DeHavllland Inc (1998 ) 74 LAC (4th) 125 (Rayner) at p
128 as follows
There lS a strong pollcy reason to honour the terms of
"last chance" agreements as I pOlnted out In my earller
award between the partles Even If there lS some
resldual power In the arbltrator to modlfy a dlscharge
In the face of language slmllar to paragraph (6) , and I
have grave doubts as to whether any such resldual power
eXlsts, one must keep In mlnd the reasons for "never-
never" or "last chance" letters They permlt the
employee to have one flnal opportunlty to keep hls Job
and they permlt both partles, the Company and the
Unlon, to resolve cases by agreement wlthout resortlng
to the costs and uncertalnty of an adversarlal process
In my oplnlon the foremost conslderatlon that should be
In the mlnd of the arbltrator when asked to conslder
such letters should be the lntegrlty of the letter
ltself If these t yp e s of agreements are subJect to
10
modlflcatlon except In the most llmlted of
clrcumstances, they slmply wlII not be made As a
result future employees who mlght have recelved the
beneflt of one of these letters wlII be denled that
opportunlty Hence the pollcy of supportlng these
letter transcends the case of the lndlvldual grlevor
who has falled to ablde by the terms of the letter
Naturally, It lS always open to a unlon to prove that
the letter has not been breached, or perhaps to prove
that the letter was a legal nulllty from the beglnnlng
However In the face of paragraph (6 ) I do not thlnk It
lS open to the Unlon to seek a substltutlon of penalty
based on compasslonate grounds whlch lS the rellef that
I thlnk the Unlon seeks Even If I could grant such
rellef, for the reasons set out above I would not do so
In thls case no mater how sorry one feels for the
grlevor
I agree wlth the unlon that If the terms of a LCA are
contrary to the Human Rlghts Code, the fact that the unlon
and the grlevor had agreed to those terms lS lrrelevant
Thls lS because the rlghts under the Code may not be walved
or contracted out of See, Ontarlo Human Rlghts Commlsslon
v Borough of Etoblcoke, [1982J 1 S C R 202 (S C C ) , Re
-
Ontarlo Human Rlghts Commlsslon v Slmpsons Sears Ltd ,
[1985J, 23 D L R (4 th) 321 (S C C )
Therefore, the crltlcal lssue for determlnatlon lS the
lssue framed by the unlon, whether paras 10, 11 and 12 of
11
the LCA vOld because they are In vlolatlon of the Human
Rlghts Code
Employer counsel relled on a number of prlor
arbltratlon awards In whlch last chance agreements were
upheld as not vlolatlng the Human Rlghts Code Re Espanola
( Town) , (1997) 61 LAC (4 th) 149 (Marcotte) , Re Klmberly-
Clark Forest Products Inc , (2003 ) 115 LAC (4 tll) 344
(Levlnson) , Re York Reglon Dlstrlct School Board, (2004 )
128 LAC (4 tll) 317 (Craven) , Re Toronto Dlstrlct School
Board, (1999 ) 79 LAC (4 tll) 365 (Knopf) , Re A 0 Smlth
Enterprlses Ltd , (2000 ) o L A A No 573 (Tlms) , and Re
-
Labatt Brewerles Ontarlo, (2002 ) 107 LAC (4 tll) 126
(Barrett)
In Re Espanola (Town) , (supra) the LCA provlded, lnter
alla, that "Should Mr Howe commence drlnklng whlch
lnterferes wlth hls performance or causes hlm to mlSS t lme ,
he shall be dlsmlssed forthwlth, and he shall not have the
rlght to grleve such dlsmlssal, nor shall the unlon present
a grlevance on hls behalf" On a reVlew of the eVldence,
the arbltrator concluded that the grlevor breached the LCA
In that "on two occaSlons the grlevor dld drlnk alcohol
12
whlch consumptlon caused hlm to mlSS work " The lssue was
whether the LCA wa s contrary to the Human Rlghts Code At
p 170-172, the Board wrote
Further, we note that the 1990 Letter of Agreement does
not requlre the grlevor to never drlnk alcohol as a
condltlon of relnstatement Rather, It provldes for
the grlevor not to mlSS work as a result of consumptlon
of alcohol That lS, we do not flnd that In
accommodatlng the grlevor's handlcap, the Employer
lmposed a standard that lS hlgher than applled to other
employees The partles agreed that as a condltlon of
relnstatement, the grlevor was to be absent no more
than the average absenteelsm In hls department In Re
Sault Ste Marle (Joyce) supra, the arbltrator, as one
condltlon of relnstatement, dlrected that the grlevor,
who suffered from alcohollsm, was to malntaln a level
of attendance at work whlch "durlng the two-year perlod
must be no worse that the average for employees In hls
department " In Re Sault Ste Marle (Hlnnegan) the
arbltrator states at pp 13-4 "reasonable attendance
lS normally measured by the employee's level of
attendance compared wlth the average for other
employees In hls department over a reasonable perlod of
tlme " In the oplnlon of Judge Steele at p 2 [p 162
o A C ] of hls declslon In o P S E U , supra, a
"fallure to meet the average attendance record could be
grounds for dlsmlssal of any employee and was therefore
not dlscrlmlnatory", but see Judge MacFarland's
declslon In that same case, at p 4 [p 163 o A C ]
that thls standard was not requlred of other employees
and thus was not lawful We prefer the Vlew of
arbltrator Joyce, whlch Vlew lS generally held by
arbltrators as lndlcated by arbltrator Hlnnegan, that a
proper standard to measure reasonable attendance lS an
employee's departmental average of absenteelsm In so
flndlng, we note that the grlevor's absenteelsm over
13
the course of hls employment subsequent to Aprll 30,
1990, was related to hls alcohollsm on the occaSlon of
hls October 1991 accldent We further note, as was Mr
Sheppard's undlsputed testlmony, that exceSSlve
absenteelsm was a factor In the Employer's lnltlal
declslon to dlscharge hlm prlor to Ap r II , 1990 In the
result, we do not flnd that the standard of reasonable
attendance as measured by the average rate of
absenteelsm In the grlevor's department was a hlgher
standard than lmposed on other employees In all the
Clrcumstances of the case before us
As to whether or not the grlevor was subJected to
closer scrutlny than were other employees, we note that
In each of the years followlng hls Aprll 30, 1990
relnstatement, hls rate of absenteelsm, however
measured, greatly exceeded hls department average
Slmply stated, that the Employer tolerated thls
Clrcumstance for some three years mllltates agalnst any
argument of closer scrutlny of the grlevor arlslng from
the 1990 Letter of Agreement
In the result, and based on all the foregolng, we do
not flnd that the Employer, In the partlcular
Clrcumstances of the matter before us, falled to meet
ltS obllgatlon to accommodate the grlevor by way of hls
handlcap We flnd, also, that based on the legltlmate
and real health and safety requlrements attendlng the
grlevor's work clrcumstance, that to relnstate the
grlevor to the publlc works department would lead to
undue hardshlp We also flnd that, In regard to the
matter of accommodatlon, the grlevor has falled to
fulflll hls obllgatlon to seek out successful treatment
of hls treatable handlcap condltlon We also flnd that
the requlrement In the 1990 Letter of Agreement for the
grlevor to not be absent at a rate hlgher than hls
annual departmental average lS reasonable and In llne
wlth a recognlzed arbltral Vlew of that whlch
14
constltutes a reasonable standard of attendance In
cases of relnstatement where the lssue lnvolves
exceSSlve absenteelsm
(emphasls added)
In Re Klmberly Clark Forest Products Inc , (supra) , the
grlevor was subJect to a LCA whlch requlred hlm, lnter
alla, to abstaln from the use of non-prescrlbed drugs for
36 months and to provlde urlne samples on an unannounced
basls at the employer's request The grlevor was
dlscharged pursuant to the LCA The lssue before the
arbltrator was whether the requlrements In the LCA breached
constltuted bona flde occupatlonal requlrements (BFOR) for
purposes of the Human Rlghts Code The arbltrator
concluded that they were At p 367 he concluded
[30] To summarlze, I conclude that the grlevor actlvely
smoked marlJuana contrary to hls commltment In the LCA
I further conclude that the requlrement that the
grlevor abstaln from uSlng non-prescrlbed drugs for 36
months, the requlrement that he submlt to drug testlng
on an unannounced basls for the same perlod and the
partles' agreement that dlscharge wlll be the
approprlate penalty should the test results lndlcate
the presence of non-prescrlbed drugs are BFORs
Consequently, the Code does not prohlblt the Company
from relYlng on the prescrlbed penalty of dlscharge In
the LCA and the LCA clrcumscrlbes my Jurlsdlctlon to
Substltute another penalty for the dlscharge In these
partlcular Clrcumstances
(emphasls added)
15
In Re York Reglon Dlstrlct School Board, (2004 ) 128
LAC (4th) 317 (Craven) the grlevor was dlscharged on the
grounds that he had breached a LCA In several respects At
p 324 the arbltrator found as follows
I am satlsfled that In respect at least of hls fallure
to follow the reportlng requlrements of February 26,
the grlevor was In breach of the "last chance"
agreement It lS not necessary to determlne whether
thls amounted to a "substantlal" breach, because It lS
abundantly clear that the grlevor's fallure to attend
at work on February 26 and 27 was a sufflclently
substantlal breach of the "last chance" agreement
Item 3 of the agreement refers to "any unacceptable or
unauthorlzed absence or lateness " The grlevor's
absences on February 26 and 27 were due to hls
consumptlon of alcohol on February 26
At pp 327-328, arbltrator Craven consldered the lssue
to be, whether the grlevor's contlnued absences and hls
fallure to glve tlmely notlce of hls absences, caused undue
hardshlp to the employer
In my oplnlon thls hlstory demonstrates conslderable
effort by the Employer to accommodate the grlevor's
dlsablllty, to provlde opportunltles for
rehabllltatlon, and to motlvate the grlevor to
undertake and commlt to ongolng treatment Desplte
these accommodatlons, and desplte the grlevor's
repeated efforts to secure medlcal treatment and to
draw on the support of AA, there have been frequent
relapses
16
The Employer led eVldence to the effect that the
grlevor's absences and In partlcular hls fallure to
provlde tlmely notlce of hls lnablllty to attend at
work, have created dlfflcultles In schedullng and In
arranglng for the necessary work to be performed,
especlally when hlgh school caretakers have been
detalled to work In elementary schools In antlclpatlon
of the grlevor's attendance at work I flnd that the
grlevor's absences and fallures to report have lmposed
hardshlp on the Employer
There lS eVldence, therefore, of conslderable efforts
on the Employer's part to accommodate the grlevor's
dlsablllty, and eVldence too of efforts by the grlevor
to address hls alcohollsm accompanled by several
relapses The questlon remalns whether the Employer
has accommodated the grlevor to the pOlnt of undue
hardshlp To put It bluntly, when lS enough, enough?
At p 330, he concluded
To the extent that the grlevor's poor attendance and
fallure to comply wlth reportlng requlrements were
beyond hls control, the Employer was entltled to
termlnate the grlevor In the absence of a demonstrated
capaclty for or clear prognosls of future lmprovement
The Employer was obllged to accommodate the grlevor's
dlsablllty to the pOlnt of undue hardshlp That pOlnt
was reached when, after a lengthy hlstory of
unsuccessful attempts at accommodatlon, the further
hardshlp necessarlly occasloned by addltlonal
accommodatlon was not offset by substantlal eVldence of
a good prospect for future performance
For all these reasons, the grlevance must be denled
(emphasls added)
17
In re A 0 Smlth Enterprlses Ltd (Supra) , the
arbltrator noted at p 6 that the grlevor had breached the
LCA In the followlng manner
18 There lS no dlspute between the partles that the
grlevor breached the provlslons of the October 1999
agreement He falled to partlclpate In the recommended
after-care program, as requlred by paragraph 6 He dld
not produce a doctor's note for hls slck days, contrary
to paragraph 8 of the agreement Flnally, hls absence
on March 10, and Aprll 10-18, 2000, exceeded "one
occaSlon every two months" as set out In paragraph 10
of the agreement The eVldence establlshes that the
average rate of absenteelsm In the plant lS less than
SlX days per year
The employer's posltlon lS set out at p 7 as follows
27 The Company further denles that the terms of the
last chance agreement constltute dlscrlmlnatlon
prohlblted by the Human Rlghts Code In any event,
Counsel suggests that the eVldence establlshes that the
Company has accommodated the grlevor up to the pOlnt of
undue hardshlp The Company asks me to conslder ltS
ongolng unsuccessful attempts to asslst the grlevor In
llght of what It characterlzes as the absence of
rehabllltatlve potentlal here, and to deny the
grlevance
The unlon's posltlon was as follows (p 7 )
29 The Unlon argues that the grlevor suffers from
alcohollsm, a handlcap wlthln the meanlng of the Human
Rlghts Code It acknowledges that the grlevor's
attendance has posed serlOUS problems for the Company
and that the Company has made slgnlflcant efforts over
18
the years to accommodate hlm The Unlon's
representatlve submlts, however, that although the
partles entered lnto the last chance agreement here In
lssue In good falth, the terms of such agreement
constltute dlscrlmlnatlon prohlblted by the Code, and
the agreement lS thus vOld and unenforceable
30 The Unlon argues that the agreement dlscrlmlnates
agalnst the grlevor on the basls of handlcap In that It
subJects hlm to "unusual burdens " Speclflcally, the
Unlon asserts that the agreement lS dlscrlmlnatory In
requlrlng that the grlevor advlse the Company of any
medlcatlons he may take, and In requlrlng that he
malntaln the plant average attendance record or face
dlscharge Most lmportantly, the Unlon submlts that
the agreement vlolates the Code In denYlng the grlevor
the rlght under sectlon 48 (1 7) of the Labour Relatlons
Act, 1995 and Artlcle 8 08 of the collectlve agreement
to have revlewed the penalty lmposed on hlm by the
Company The Unlon further malntalns that the Company
falled to accommodate the grlevor to the pOlnt of undue
hardshlp, and asks me to conclude that the termlnatlon
of the grlevor's employment pursuant to the last chance
agreement cannot be upheld
Followlng a reVlew of the eVldence at p 10 arbltrator
Tlms wrote
43 Whlle It lS for the Company to establlsh that It
has accommodated the grlevor to the pOlnt of undue
hardshlp, ltS efforts must be vlewed In the context of
what Arbltrator Rayner referred to as hls
"rehabllltatlon potentlal " (See Re O-Pee-Chee
Company, supra)
44 The grlevor returned to work In January 2000
pursuant to the last chance agreement The eVldence lS
19
clear that he resumed drlnklng shortly after hls
return, and that he was In breach of the terms of the
agreement by February 2000
45 The Unlon asks that I relnstate the grlevor on a
last chance basls, wlth whatever condltlons I Vlew as
approprlate Nelther the Unlon nor the grlevor
suggested anythlng speclflc that the Company had falled
to do In fulfllment of ltS statutory obllgatlons
46 I am of the Vlew after conslderlng all of the
eVldence and the submlsslons of the partles, that the
grlevance must be denled
47 The grlevor falled to comply wlth the terms of the
last chance agreement, and he and the partles agreed
thereln that termlnatlon of employment would result
Even If the provlslons of the sald agreement offend
sectlon 5 of the Human Rlghts Code, I must conclude
that such dlscrlmlnatlon would be excused In the
present case by sectlon 17 of the Code
48 It was agreed by the partles that regular
attendance at work lS an essentlal duty of the
grlevor's Job, and I am of the Vlew that the Company
has establlshed that It has made efforts to accommodate
the grlevor to the pOlnt of undue hardshlp
(emphasls added)
The unlon reI led on two Judlclal authorltles In support
of ltS posltlon that the provlslon of the LCA the grlevor
had breached was contrary to the Human Rlghts Code, and
therefore vOld
20
In Re Ontarlo Human Rlghts Commlsslon v Galns Pet
Foods Corp (1993) 16 o R (3d) 290 (Ont DlV Ct ) The LCA
In questlon was held to be contrary to the Ontarlo Human
Rlghts Code In two ways, one of whlch lS dlrectly relevant
to the lnstant case The LCA provlded, lnter alla, as
follows
(a) Durlng the next twelve (12 ) months of your
employment you wlll be expected to malntaln a
level of attendance equal to or better than the
average for the hourly rated employees In the
plant The plant average wlll be calculated on a
rolllng 12-month basls
Fallure to meet the above requlrements at any tlme wlll
result In the termlnatlon of your employment
The grlevor was termlnated for non-compllance wlth that
undertaklng At p 291-92, the court wrote
In cross-examlnatlon, Mr Gerber, dlrector of
operatlons of the respondent company at all relevant
tlmes, candldly conceded that but for Ms Black's
absence from November of 1984 to Aprll of 1985, due to
cancer, the restrlctlve condltlon would not have been
lmposed upon her (See transcrlpt of eVldence, vol 5,
p 674, Ilne 14 to p 675, Ilne 3 )
It was conceded by the respondents throughout that
cancer constltuted a handlcap wlthln the meanlng of s
4 (1) of the Ontarlo Human Rlghts Code, R S 0 1990, c
H 19(the "Code" )
21
Based upon the clear admlsslon of Mr Gerber, It lS
apparent that lrrespectlve of Ms Black's prlor hlstory
of absenteelsm, the proxlmate If not prlmary cause of
the restrlctlve condltlon In the Aprll 29 letter arose
dlrectly from Ms Black's absence due to her
dlsablllty Whlle It certalnly would have been open to
the respondents to warn Ms Black, upon her return to
work In Aprll of 1985, that she was requlred to
malntaln a reasonable level of attendance, absent
whlch, she would be termlnated, the lmposltlon of the
restrlctlve condltlon was dlscrlmlnatory, stemmlng as
It dld dlrectly from her absence due to handlcap see
Engell V Mount Slnal Hospltal (1989) , 11 C H R R D/68
(Ont Bd Of Inqulry) , Glengarry Industrles/Chromalox
v U S W A , Local 6976 (1989) 3 LAC (4 th) 326
(Ont ) , and General Tlre Canada Ltd v U R W , Local
536 (1986) , 26 LAC (3d) 95 (Ont )
Although the respondents submltted that the restrlctlve
condltlon amounted to nothlng more than a warnlng, we
do not agree It was a condltlon not requlred of or
lmposed upon any other employee and It carrled wlth It
the sanctlon of lmmedlate termlnatlon for non-
compllance
Indeed, Ms Black's subsequent fallure to Ilve up to
that condltlon led dlrectly to her termlnatlon on
January 6, 2986 The letter of termlnatlon, found at
tab 6 of the Appeal Book, leaves Ilttle doubt that Ms
Black's dlsmlssal stemmed In large measure from her
fallure to comply wlth the terms of the restrlctlve
condltlon, a condltlon whlch we have found to be
dlscrlmlnatory and In vlolatlon of her rlghts under the
Code
It should be noted that although the second paragraph
of the termlnatlon letter beglns wlth the words "we
agreed at that tlme (Aprll 29, 1985) that your
22
contlnued employment wlth Galnes", the record lS clear
that Ms Black, at that t lme , slmply agreed to do the
best she could Her acceptance of these condltlons was
to that extent quallfled Regardless, even If It could
be sald that she agreed to the restrlctlve condltlon,
such agreement would be unenforceable see Ontarlo
(Human Rlghts Commlsslon) v Etoblcoke (Borough) ,
[1982] 1 S C R 202, 132 D L R (3d) 14
Thus, we are satlsfled that Ms Black's termlnatlon was
both dlrectly and substantlally Ilnked to the
lmposltlon of the restrlctlve condltlon whlch we have
found to be dlscrlmlnatory
(emphasls added)
In OPSEU v Ontarlo (Mlnlstry of Communlty and Soclal
Servlces) [1996] o J No 608 (Ont DlV Ct ) , para 4 of
the LCA provlded as follows
4 The Grlevor's attendance record wlll be revlewed
every SlX months for a perlod of two years
followlng the date upon whlch the Grlevor lS re-
lnstated to hls employment
If In any SlX month perlod the Grlevor falls to meet or
surpass the average attendance record of the
department, he wlll be subJect to dlsmlssal pursuant to
the terms of thls agreement
The grlevor falled to meet the average attendance
record of the department for the 6 month perlod endlng
Aprll 27, 1993 and was termlnated
23
The unlon's argument there was very slmllar to the one
made before me
11 The Unlon, on behalf of Mr Blackhall, argues that
thls paragraph 4 , In partlcular, lS dlscrlmlnatory In
that Mr Blackhall lS requlred, by ltS terms, to
perform to a standard not requlred of one-half of the
other employees wlthln hls department, the departmental
average representlng the mldpolnt wlth half the
employees above the average and the other half below
It
MacFarland J for the maJorlty held
13 We are of the Vlew that paragraph 4 lS
dlscrlmlnatory because at the very least, It requlres
Mr Blackhall whose absenteelsm was known to be caused,
at least In part, by hls handlcap, to meet a standard
not requlred of other employees and subJects hlm to a
reVlew process when other employees slmllarly sltuated
are not
14 The eVldence lS clear that In 1991 when Mr
Blackhall was lnltlally termlnated he has been absent a
great deal of tlme due to hls obsesslve compulslve
dlsorder and the employer was aware of It It lS also
clear that In lmposlng paragraph 4 of the settlement
agreement on Mr Blackhall they dld so - at least, In
part, because of hls absence due to a handlcap wlthln
the meanlng of the Code In so dOlng, the employer
dlscrlmlnated agalnst Mr Blackhall wlthln the meanlng
of the case of Re Ontarlo Human Rlghts Commlsslon v
Galns Pet Food (1993) , 16 o R (3d) 290 (On DlV Ct )
The fact that Mr Blackhall agreed to the condltlon
does not asslst the employer, as such agreement lS
unenforceable Galns Pet Food at p 292
24
In the present case, It lS lmportant to note the
requlrement In the LCA whlch the grlevor falled to comply
wlth She was requlred to provlde medlcal documentatlon
for her absence on September 13, 2005 wlthln 3 calendar
days upon returnlng to work She returned to work on
September 14th Therefore, he was requlred to provlde the
documentatlon no later than September 17th She dld so only
on September 28th That delay was the basls of her
termlnatlon Thls lS eVldenced from the letter of
termlnatlon dated October 3, 2005 whlch In part reads
I have consldered all the lnformatlon that lS avallable
to me, and have determlned that dlsclpllnary actlon lS
warranted I note that you entered lnto Mlnutes of
Settlement In February 2004, whereln you agreed, In
paragraph 10, to "provlde documentatlon substantlatlng
such absence wlthln three (3) calendar days upon your
return to work" and were warned, In paragraph 11, that
fallure to meet any of the requlrements of the
agreement for a two (2 ) year perlod shall result In
automatlc termlnatlon Because you falled to provlde
the medlcal documentatlon for your September 13, 2005
absence In accordance wlth paragraph 10, your
employment lS termlnated based upon your breach of
paragraph 11 of the Mlnutes of Settlement
On a reVlew of the authorltles reI led upon by the
partles, the approprlate approach In cases of thls nature
lS as follows
25
(1 ) Flrst, It must be determlned whether the grlevor
breached the standard or requlrement In the LCA as
alleged by the employer
(2 ) Second, It must be determlned whether or not the
LCA subJected the grlevor to a standard or
requlrement whlch lS hlgher or more onerous than
that lmposed on other employees
(3 ) Thlrd, If the answer lS In the afflrmatlve, I must
determlne whether the hlgher standard or requlrement
was lmposed on the grlevor, In whole or In part,
because of her dlsablllty If the answer lS "yes",
the standard or requlrement lS dlscrlmlnatory and
vlolates the Human Rlghts Code
(4 ) Flnally, In the event that the standard or
requlrement lS found to be dlscrlmlnatory, I must
proceed to conslder whether or not that standard or
requlrement lS nevertheless valld and enforceable
because It constltutes a bona flde occupatlonal
requlrement (BFOR) and/or because the requlrement
represents the pOlnt of undue hardshlp for the
employer
26
The declslon In Re Toronto Dlstrlct School Board
(supra) relled upon by the employer lS a good lllustratlon
of thls approach
At pp 383-384, arbltrator Knopf wrote
Therefore, on the narrow questlon of whether there was
Just cause to dlscharge, the Last Chance Agreement
dlrects In paragraph 8 that any breach of condltlons of
the agreement would be deemed to be for Just cause
These partles agreed In submlsslons before me that the
grlevor has breached condltlons of the Agreement
Therefore, on the basls of the agreed facts and glvlng
full respect to the voluntarlly executed terms of the
Last Chance Agreement, It must be concluded that Just
cause for dlscharge has been proven In thls case But
thls does not end the matter The Unlon has argued
that the Agreement, In ltself, lS a vlolatlon of the
Human rlghts Code In that It sets up dlscrlmlnatory
condltlons agalnst the grlevor on the basls of her
handlcap, that lS, her addlctlon to alcohol The Unlon
relles on the reasonlng In the Fantom Technologles Inc
case, supra, at pages 246-248 and followlng
Counsel reI led on two declslons of the OntarlO
Dlvlslonal Court The flrst was Re Ontarlo Human
rlghts CommlSSlon and Galnes Pet Foods Corp (1994) , 16
o R (3d) 290 In the Galnes case, the complalnant had
a restrlctlve condltlon lmposed on her when she
returned to work after a slx-month absence due to a
serlOUS lllness The condltlon was that she would be
"expected to malntaln a level of attendance equal to or
better than the average of the hourly rated employees
In the plant" [at p 291 ] Fallure to meet that
lnstructlon would "result In the termlnatlon of [her]
employment" The court noted that lrrespectlve of the
complalnant's hlstory of absenteelsm, whlch was
extenslve, the prlmary cause of the restrlctlve
condltlon arose dlrectly from her dlsablllty As It
transplred, the complalnant falled to Ilve up to the
condltlon and was termlnated The Court held that even
If the complalnant has accepted the condltlon, "such
27
agreement would be unenforceable", at p 292 In so
holdlng, the Court relled upon the declslon of the
Supreme Court of Canada In Ontarlo (Human Rlghts
Commlsslon) v Etoblcoke (Borough) , [1982] 1 S C R
202
In the Etoblcoke case, the Supreme Court had before It
a mandatory retlrement clause In a collectlve
agreement It was argued that as the partles had
negotlated the condltlon and that It was based, In
part, on the demands of the partlcular occupatlon, It
ought to be respected as a bargaln between the partles
Mr Justlce McIntyre, for the Court, held that to glve
effect to that argument "would be to permlt the partles
to contract out of the provlslons of The Ontarlo Human
Rlghts Code It lS clear from the authorltles,
both In Canada and In England, that partles are not
competent to contract themselves out of the provlslons
of such enactments and that contracts havlng such
effect are vOld, as contrary to publlc pollcy" [at p
213 ]
The Dlvlslonal Court In Galnes [Ontarlo (Human Rlghts
Commlsslon v Galnes Pet Foods Corp (1993) , 50
C C E L 315, 28 C H H R D/256, 94 C L L C 17, 004,
sub nom Black v Galnes Pet Foods Corp , 16 o R (3d)
290, 44 A C W S (3d) 758 ] held that the complalnant's
termlnatlon was both "dlrectly and substantlally Ilnked
to the lmposltlon of the restrlctlve condltlon whlch we
have found to be dlscrlmlnatory" [at p 292 ] and
therefore unenforceable The Court held that the
complalnant's rlghts under the Code were vlolated,
because In termlnatlng her the company took lnto
account her slx-month absence due to her cancer The
Court also noted the complalnant's lengthy absenteelsm
record and held that "the law lS clear that the
prohlblted ground of dlscrlmlnatlon need not be the
only reason for the actlon taken, as long as It forms
one of the reasons", at p 293
The Galnes declslon was followed by another panel of
the OntarlO Dlvlslonal Court In o P S E U V OntarlO
(Mlnlstry of Communlty and Soclal SerVlces )
(unreported, February 21, 1996, Court Flle No
544/95) In that case the grlevor suffered from an
obsesslve compulslve dlsorder, whlch was a handlcap
28
wlthln the meanlng of the Code The grlevor had been
dlsmlssed In 1991 because of absenteelsm related to hls
condltlon and was relnstated on terms Paragraph 4 of
the Settlement provlded that If he falled to meet or
surpass the average attendance record of the department
In any slx-month perlod, he would be subJect to
dlsmlssal In March, 1993, he falled to meet the
average and was dlsmlssed The holdlng of the
Dlvlslonal Court, and It lS partlcularly relevant to
thls case, was that the grlevor was requlred to meet a
standard not requlred of other employees, and subJected
hlm to a reVlew process when other employees slmllarly
sltuated were not That constltuted dlscrlmlnatlon on
the basls of dlsablllty contrary to the Code And, as
In Galnes, the Court held that the fact that the
grlevor agreed to the condltlon does not asslst the
employer, "as such agreement lS unenforceable"
Arbltrator Knopf concluded as follows
I am of the oplnlon that the declslon In Galnes, supra,
and In o P S E U v OntarlO (Mlnlstry of Communlty and
Soclal Servlces), supra, declde the lssue In thls case
That lS, a condltlon was lmposed upon Comanluk because
of hls handlcap, whlch subJected hlm to a reVlew
process partlcular to hlm, and not lmposed upon hls
fellow employees And the fact that he agreed to It,
and was advlsed by hls unlon In dOlng so, does not
render the Agreement any less unenforceable, see the
declslon of the Supreme Court of Canada In Etoblcoke,
supra The passage In Labatt's, supra, does not state
the law In Ontarlo, and appears to be contrary to the
rullng In Etoblcoke, supra
Flnally, counsel for the Company argued that paragraph
5 ousted entlrely the Jurlsdlctlon of an arbltrator to
hear thls case That lS, If there was a breach of the
Code, then the proper place for Comanluk to complaln lS
elther In the OntarlO Courts or before the Ontarlo
Human Rlghts Commlsslon He could not come to
arbltratlon because he agreed, In paragraph 5 of the
Agreement that he would not I am of the oplnlon that
the Agreement not to grleve or to resort to the
arbltratlon process, lS not a provlslon that lS
severable from the rest of paragraph 5 Indeed, It lS
an essentlal part of It, and the whole lS vlolatlve of
29
the Code and unenforceable for the reasons set out
above
The prellmlnary obJectlon lS dlsmlssed and It lS
ordered that Comanluk be returned to work upon recelpt
of thls Award Thls lS not a case for compensatlon
(emphasls added)
Havlng concluded that the requlrement of the LCA
breached by the grlevor was dlscrlmlnatory, however, the
arbltrator stated that such flndlng was not the "end of the
matter" She went on to conslder the employer's argument
that the LCA term In questlon constltuted an accommodatlon
to the pOlnt of undue hardshlp She wrote at pp 387-388
Agaln, the recltals In the Agreement set out a
background of work performance problems and alcohol
abuse In the workplace Thls led the partles to the
mutual agreement that the sltuatlon could not contlnue
Thls lS understandable In any workplace, but
partlcularly so In the context of a publlc educatlonal
lnstltutlon The eVldence dlscloses that by November
1997 there was a recognltlon that the grlevor's
presence at the work slte could not be contlnued and
should not be resumed unless and untll abstlnence and
other condltlons could be malntalned Thls was a
"reasonable" response to a dlfflcult sltuatlon
Further, the partles recognlzed that thls response was
taken after "every reasonable effort to accommodate"
the grlevor had already been provlded (See paragraph
(lV) of the Agreement ) To ask that the reasonable
terms and condltlons of the Agreement be set aSlde
after havlng already made "every reasonable effort to
accommodate", the grlevor would be puttlng the Employer
In a posltlon of undue hardshlp It would negate the
efforts made to date and It would render meanlngless to
thls grlevor and all others In her sltuatlon the
lmportance of a last chance agreement
30
Therefore, I must conclude that the eVldence
establlshes that the Employer had accommodated thls
grlevor up to the pOlnt of undue hardshlp at the tlme
the Agreement was slgned Further, at the tlme of
termlnatlon the Agreement can be seen as an addltlonal
accommodatlon To expect any further accommodatlon
would be puttlng thls employer to undue hardshlp The
test lS not whether anythlng else could have been done
There lS always somethlng more that could be done for a
person In dlstress There lS always the hope that one
more try or one more treatment wlll turn a sltuatlon
around But the Human Rlghts Code does not demand that
dlsabled employees be glven every concelvable
opportunlty It demands that the employee be
accommodated to the pOlnt of undue hardshlp by the
employer The facts here establlsh that the Employer
has met the burden of provlng that level of
accommodatlon
(emphasls added)
It lS apparent that In Re Toronto Dlstrlct School Board
the LCA provlslon was upheld, although found to be
dlscrlmlnatory and contrary to the Code, only because on
the partlcular eVldence the Board concluded that the
employer could not make any further accommodatlon, wlthout
sufferlng undue hardshlp, wlth regard the grlevor's
lnablllty to attend work to an acceptable level
The same lS true of the declslon In Re Labatt Brewerles
Ontarlo, (2002 ) 107 LAC (14 th) 126 (Barrett) There the
grlevor had a heroln addlctlon In a LCA all partles had
31
agreed that "the company has fulfllled ltS duty of
reasonable accommodatlon under the Human Rlghts Code and
the unlon shall not argue for any further accommodatlon of
Slmon by the Company" The unlon's posltlon lS set out at
p 138
It lS the posltlon of the Unlon that several provlslons
of the last chance agreement dlscrlmlnate agalnst the
grlevor due to hls handlcap He has restrlctlons
placed on hlm that are not lmposed on others
Paragraph 4 provldes that he cannot be under the
lnfluence of drugs whlle not at work The testlng
provlslon lS not lmposed on other employees, and
testlng can measure drug use outslde of worklng hours
Paragraph 7 requlres that he malntaln the plant average
absenteelsm rate, whlle paragraph 9 takes away hls
rlght to have an arbltrator exerClse her Jurlsdlctlon
to substltute a lesser penalty than dlscharge for a
breach
In the LCA, the grlevor had agreed to lmmedlately co-
operate wlth a company request to provlde a blood or urlne
sample when requested, for testlng for drugs He was
dlscharged because he refused to provlde a urlne sample
when requested
At pp 142-143 the arbltrator wrote
The provlslon of the last chance agreement that Mr
Bartolo vlolated was one that was reasonable and bona
flde In the clrcumstances, and not dlscrlmlnatory In
the llght of hls acknowledged drug addlctlon and the
obvlous requlrement that people be drug-free at work
I do not thlnk It lS necessary for me to examlne every
clause In the last chance agreement for slgns of
32
dlscrlmlnatlon arlslng out of handlcap The one that
was vlolated was reasonable and bona flde
At p 143 she concluded that the employer had
accommodated the grlevor to the pOlnt of undue hardshlp
I flnd that the Company had accommodated the grlevor's
handlcap up to the pOlnt of undue hardshlp at the tlme
It termlnated hlm It put up wlth a lengthy dlsclpllne
and absenteelsm hlstory, It accommodated two four-month
and one seven-month leaves of absence for
rehabllltatlon programs, the last two of whlch were
pald for by the Company On the last two occaSlons,
hls return to work hours were accommodated to meet hls
program requlrements wlthout loss of pay And, of
course, there lS the very lmportant acknowledgement
that the last accommodatlon was sufflclent
(emphasls added)
Turnlng to the other arbltratlon declslons relled upon
by the employer, In Re Espanola (supra), It was found that
the grlevor was not subJected to a hlgher standard, and
further that he had been accommodated to the pOlnt of undue
hardshlp
In each of the other declslons reI led upon by the
employer, the declslon turned on the fact that the
requlrement lmposed on the grlevor was a bona flde
occupatlonal requlrement and/or that the employer had
accommodated the grlevor to the pOlnt of undue hardshlp
33
Turnlng to the lnstant case, the flrst of the four
steps I have set out above lS easy to apply Slnce the
partles agree that the LCA was breached by the grlevor
She was requlred to provlde documentatlon relatlng to an
absence wlthln 3 days of her return to work She falled to
meet the 3 day tlmellne
As for the second step, employer counsel argued that
the 3 day tlme Ilmlt was not a requlrement pecullar to the
grlevor Reference was made to artlcle 12 4 of the
collectlve agreement whlch lS set out In the agreed facts
(p 5 supra)
I agree wlth unlon counsel that the LCA requlrement In
questlon lS very dlfferent and more onerous than that
contalned In artlcle 12 4 That artlcle lS about
entltlement to leave wlth pay for absences caused by
slckness or lnJury It does not lmpact on the lssue of
Just cause for dlsclpllne and dlscharge In any event, for
absences of less than 5 days, It glves the employer a
dlscretlon to requlre a medlcal certlflcate It does not
requlre a certlflcate In all cases of absence due to
slckness, as was the case In the grlevor's LCA Flnally,
34
artlcle 12 4, unllke the LCA, does not stlpulate any tlme
deadllne for productlon of a medlcal certlflcate
Therefore I conclude that the LCA lmposed a hlgher standard
on the grlevor
Movlng on to the next step In the analysls, employer
counsel pOlnted out that whlle the grlevor's absence on the
day In questlon was due to a legltlmate lllness, It had
nothlng to do wlth her dlsablllty, l e her alcohol
addlctlon Her fallure to produce medlcal documentatlon
wlth 3 days was not related to her dlsablllty elther Thus
she submltted, that the LCA requlrement the grlevor
breached was not Ilnked to the dlsablllty and therefore
could not held to be contrary to the Human Rlghts Code
In my Vlew, the fact that the breach ltself was not
related to the dlsablllty lS lrrelevant That lS not the
test The test lS whether or not the hlgher standard was
lmposed on the grlevor because of her dlsablllty See the
Court declslons In Re Galnes Pet Foods and Re OPSEU
(supra) To lllustrate, assume that a LCA requlres that X
be not absent more than 5 days In any calendar month, a
condltlon not requlred of other employees The requlrement
35
was lmposed on X In an attempt to control her absenteelsm
due to her dlsablllty l e a drug addlctlon X exceeds the
5 day Ilmlt followlng an auto accldent Even though the
breach was caused by an absence unrelated to X's
dlsablllty, It would nevertheless be dlscrlmlnatory because
X would not have been subJected to that 5 day tlme Ilmlt,
but for her dlsablllty The same lS true In the present
case But for her addlctlon, the grlevor would not have
been subJect to the requlrement she breached The employer
dld not argue otherwlse That lS the Ilnk that renders It
dlscrlmlnatory on the grounds of dlsablllty Thus In
Galnes Pet Foods (supra) , the Court reasoned " It lS
apparent that lrrespectlve of Ms Black's prlor hlstory of
absenteelsm, the proxlmate If not prlmary cause of the
restrlctlve condltlon In the Aprll 29 letter arose dlrectly
from Ms Black's absence due to her dlsablllty" In OPSEU
v Ontarlo, the Court stated "We are of the Vlew that
paragraph 4 lS dlscrlmlnatory because at the very least, It
requlres Mr Blackhall whose absenteelsm was known to be
caused, at least In part, by hls handlcap, to meet a
standard not requlred of other employees and subJects hlm
to a reVlew process when other employees slmllarly sltuated
are not" The Court observed "It lS also clear that In
36
lmposlng paragraph 4 of the settlement agreement on Mr
Blackhall, they dld so - at least In part, because of hls
absence due to a handlcap wlthln the meanlng of the Code
In so dOlng, the employer dlscrlmlnated agalnst Mr
Blackhall wlthln the meanlng of the case of Re Ontarlo
Human Rlghts Commlsslon v Galns Pet Food, (1993) 16 o R
(3d) 290 (Ont DlV Ct)"
Based on the legal prlnclples revlewed ab ove , I
conclude that paragraph 10 of the LCA lS dlscrlmlnatory on
the basls of the grlevor's dlsablllty and offends the Code
The flnal lssue lS whether paragraph 10, although
dlscrlmlnatory, lS nevertheless enforceable on the grounds
that the requlrement lmposed on the grlevor represented the
pOlnt of undue hardshlp on the employer's duty to
accommodate, or that the requlrement constltuted a BFOR
As noted, such a result was achleved In cases such as
Toronto Dlstrlct School Board (supra) on the grounds that
the employer had reached the pOlnt of undue hardshlp In
accommodatlng the grlevor's dlsablllty In the present
case the employer dld not make an argument of undue
hardshlp Thls lS not surprlslng because on the partlcular
37
facts such an argument could not have succeeded If the
breach on the part of the grlevor had been a fallure to
meet the attendance rate lmposed on her In paragraph 10,
dependlng on the totallty of the eVldence, an argument
could have been made that the ablllty to meet that rate of
attendance was a reasonable requlrement, and that there was
no further accommodatlon the employer can make to help the
grlevor achleve that attendance rate Slmllarly, If the
requlrement breached caused the employer serlOUS
operatlonal problems, (e g fallure to glve tlmely notlce
of an absence as In Re York Reglon Dlstrlct School Board)
(supra) , an undue hardshlp argument may be made The
breach by the grlevor was not of that nature The grlevor
dld produce the requlred medlcal substantlatlon Her
breach was, she produced It late There lS slmply no
eVldence that that delay caused the employer any hardshlp
S 17 (1) and (2 ) of the Human Rlghts Code provldes
s 17 (1) A rlght of a person under thls Act lS not
lnfrlnged for the reason only that the person lS
lncapable of performlng or fulfllllng the
essentlal dutles or requlrements attendlng the
exerClse of the rlght because of handlcap
(2 ) The Commlsslon, a board of lnqulry or a court
shall not flnd a person lncapable unless It
lS satlsfled that the needs of the person
cannot be accommodated wlthout undue hardshlp
on the person responslble for accommodatlng
those needs, conslderlng the cost, outslde
38
sources of fundlng, If any, and health and
safety requlrements, If any
The fallure to produce medlcal documentatlon wlthln 3
days has no lmpact on the grlevor's ablllty to perform the
essentlal dutles of her Job Indeed, there lS no
suggestlon that the grlevor was deflclent In relatlon to
Job performance, by way of her ablllty to regularly attend
work or In any other way At least there lS no suggestlon
to the contrary It lS not concelvable (and It was not
argued) that the grlevor's fallure to adhere to the 3 day
tlme Ilmlt In produclng medlcal substantlatlon for her
absence on September 13, 2004 caused the employer any
hardshlp, let alone "undue hardshlp"
It follows that unllke In the cases reI led upon by the
employer, In the present case there lS no legal basls upon
whlch the requlrement lmposed on the grlevor, whlch I have
found to be dlscrlmlnatory, can nevertheless be found to be
enforceable Therefore the grlevor's dlscharge cannot
stand Slnce It was based on a provlslon In the LCA whlch
was contrary to the Human Rlghts Code That provlslon lS
vOld and unenforceable
39
Employer counsel submltted that In the event I flnd to
that effect, I ought nevertheless lmpose an approprlate
degree of dlsclpllne on the grlevor for her breach In the
Clrcumstances of thls case, I have no basls for dOlng that
Slnce the employer lS not entltled to rely on the LCA
provlslon, to Justlfy any dlsclpllne, the employer must
establlsh Just cause The eVldence before me does not do
that I have no eVldence that the employer requlred,
lndependent of the LCA, that the grlevor produce medlcal
substantlatlon by exerclslng ltS dlscretlon under artlcle
12 4 Even If there was eVldence that the grlevor was
under such a dlrectlon, from the employer, lndependent of
the LCA, to produce medlcal substantlatlon for her absence
on September 13 th , 2005 wlthln 3 days of her return to work,
the only facts before me are to the effect that the grlevor
represented to the employer that she attempted to get an
appolntment wlth her doctor but could not get one untll
September 23, 2005 Employer counsel submltted that the
grlevor could have gone to the emergency dept In a
hospltal or to some other medlcal cllnlc, rather than walt
for her own physlclan However, that lssue was not
Iltlgated and I have no eVldence In thls regard at all
Were there other optlons avallable to the grlevor and If
40
so, dld she have a reasonable explanatlon for not taklng
those optlons There lS slmply no eVldence before me upon
whlch I can flnd that the grlevor was culpable That lS a
matter not addressed by the partles, except by way of
employer counsel's submlsslon
In the cases where a dlsabled employee's dlscharge lS
upheld based on a LCA, arbltrators often express thelr
personal sympathy for the grlevor Arbltrators recognlze
that the employee lS denled hls Ilvellhood because of hls
dlsablllty, but that It lS a necessary result because the
employer cannot, under the law, be requlred to undertake
any more hardshlp In the present case the reverse lS
true The sympathy goes to the employer It had entered
lnto the LCA In good falth wlth a genulne deslre to asslst
the grlevor wlth regard to her dlsablllty As employer
counsel pOlnted out, the grlevor beneflted from that
agreement No doubt, It would be very frustratlng that It
flnds ltself unable to rely on the deal struck However,
desplte the good falth and the lack of fault, the Human
Rlghts Code as lnterpreted by the Courts must prevall I
have no dlscretlon but to enforce the law
41
It follows from the foregolng that the grlevance must
succeed The employer lS dlrected to relnstate the grlevor
forthwlth and to compensate her for all losses that
resul ted from her termlnatlon I remaln selzed In the
event the partles have any dlspute In lmplementlng thls
declslon
:t
Dated thls 1 day of February, 2006 at Toronto, Ontarlo
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