HomeMy WebLinkAbout2005-2549.Hyland.06-04-20 Decision
Commission de
Crown Employees
Grievance Settlement
règlement des griefs
Board
des employés de la
Couronne
Suite 600 Bureau 600
180 Dundas St. West 180, rue Dundas Ouest
Toronto, Ontario M5G 1Z8 Toronto (Ontario) M5G 1Z8
Tel. (416) 326-1388 Tél. : (416) 326-1388
Fax (416) 326-1396 Téléc. : (416) 326-1396
GSB# 2005-2549, 2005-2550, 2005-2561
UNION# 2004-0337-0001, 2004-0337-0002, 2005-0337-0007
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Ontario Public Service Employees Union
(Hyland)
Union
- and -
The Crown in Right of Ontario
(Ministry of Children and Youth Services)
Employer
BEFORE Vice-Chair
Ken Petryshen
FOR THE UNION David Wright
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
FOR THE EMPLOYER Sean Kearney
Senior Counsel
Ministry of Government Services
HEARING April 10, 2006.
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Decision
In previous decisions I have addressed gr ievances filed by Mr. Hyland in which he
claimed that the Ministry of Correctional Serv ices had failed to accommodate him properly. Mr.
Hyland has asthma and is particularly sensitive to cigarette smoke. In a decision dated June 21,
2004, I directed the Employer to place Mr. Hyland in a position at the Brookside Youth Centre
(?Brookside?) where he is employed now as a Y outh Service Officer. Brookside is now within
the Ministry of Childre n and Youth Services.
Mr. Hyland has filed accommoda tion grievances at Brookside. Prior to the hearing on
April 10, 2006, the parties attempted to resolve certain production issues, as well as issues about
particulars. The discussion of these matters continued at the hearing. One issue that the parties
did not resolve concerned the Employer?s request for medical documentation. Counsel made
submissions on this matter at the hearing and this decision addresses that issue.
The particulars provided by the Union indicate that Mr. Hyland?s complaint has two
features. The first is that Brookside?s smoking policy does not provide adequate protection for
his disability. Mr. Hyland take s the view that a policy which only prohibits ?smoking in the
presence of youth, in all buildi ngs on the facility property an d in Ministry vehicles? is
inadequate. He takes the position that the Ministry should adopt a policy prohibiting smoking on
facility grounds, like the policy th at applies to adult correctional institutions. The second feature
of Mr. Hyland?s complaint is that the Brookside polic y is not being enforced. He asserts that he
has witnessed smoking in prohibite d areas and that he has been exposed to cigarette smoke on a
number of occasions.
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The particulars refer to instances where Mr. Hyland was absent from work because of
exposures to cigarette smoke. There are a couple of occasions where it is alleged that Mr.
Hyland was absent due to stress attributable to the regular exposure to cigarette smoke and the
lack of action by management to deal with the pr oblem. Mr. Hyland is alleging, in effect, that
his experience at Brookside is no t unlike the experiences he had at the Toronto East Detention
Centre and the Toronto Jail in that his health has been affected detrimentally by exposures to
cigarette smoke resulting in absences from work. Medical evidence tendered in earlier
proceedings indicated that limited exposure to cigarette smoke could trigger an asthmatic
reaction for Mr. Hyland.
The Employer?s request for medical documentati on has two aspects.It requests that Mr.
Hyland provide a decoded OHIP summary covering th e period from June 1, 2004 to the present,
the time Mr. Hyland has been at Brookside. It also requests for the same period the clinical notes
and records of any medical practitioner, specialist and therapist that Mr. Hyland has seen.
Counsel for the Employer submitted that this reques t is reasonable in the circumstances. He
noted that the request focuses on a brief period and argued that it is necessary because Mr.
Hyland?s health is a critical feat ure of this dispute. Counsel argued that the Employer is entitled
as a matter of fairness to obtain a complete picture of Mr. Hyland?s health and that the
documentation requested is arguably relevant having regard to the issues in this case. In support
of the Employer?s position, counsel placed considerable reliance on Re OPSEU (Richard) and
Ontario Clean Water Agency, GSB 2000-1220 (Abramsky) dated June 20, 2005. Counsel also
referred to the following decisions: Derynck v. Chevalier Estate, [2002] O.J. No. 641, Re
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Ontario (Ministry of Transportation)and OPSEU (Vangou) (2005), 138 L.A.C. (4) 58
(Dissanayake),Re Greater Essex County District School Board and OSSTF, District 9 (Lebert)
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(2002), 109 L.A.C. (4) 379 (Knopf), Re University of Saskatchewan and University of
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Saskatchewan Faculty Assn. (Caulkett) (2002), 107 L.A.C. (4) 115 (Pelton) and Re Toronto
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District School Board CUPE, Loc. 4400 (2002), 109 L.A.C. (4) 20 (Shime).
The Union does not dispute that Mr. Hyland?s health is an issue in this proceeding and
that the Employer is entitled to some medical documentation for the period suggested by the
Employer. However, counsel for the Union took the position that the breadth of the Employer?s
request is extreme and unnecessary in the circumst ances of this case. Counsel argued that the
balancing of Mr. Hyland?s righ t to privacy and the Employer?s interest in securing arguably
relevant medical information could be met wit hout providing the Employer with Mr. Hyland?s
complete medical history since June of 2004. Counsel noted that Mr. Hyland has other medical
issues that are unrelated to this dispute. He has not been absent from work because of the other
medical issues and he has not made a claim agai nst the Employer with respect to them. Counsel
argued that the primary issue in this case, as it was in other proceedings involving Mr. Hyland, is
whether the Employer has taken reasonable precautions for his safe ty, given his disability. He
submitted that this should be the focus of any order to produce medical documentation. Counsel
also submitted that the facts in Re OPSEU (Richard),supra, are fundamentally different from the
facts in this proceeding and theref ore this matter warrants a different approach. As an alternative
to the Employer?s request, counsel submitted that a medical report that is responsive to specific
questions could be obtained from Mr. Hyland?s fa mily doctor. Without setting out all of the
questions counsel proposed to ask the doctor, the report would focus on any treatment the grievor
received for asthma, for exposures to cigarette smoke, for exposures to cats and dogs and any
treatment relating to stress. The doctor would be asked to provide detailed information on these
matters. Counsel argued that this approach would satisfy the interests of both parties.
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Since both counsel focused on Re OPSEU (Richard),supra, I will review this decision in
some detail. The Union claimed that due to ha rassment at the workplace between February of
1998 and mid-2000, the grievor was unable to work because of illness caused by stress and
anxiety. It was clear that the grievor had experienced stress and anxiety, incl uding panic attacks,
predating the allegations agains t the employer. The employer requested the grievor?s decoded
OHIP summary from January of 1996, two years prio r to the first alleged occurrence at work,
until May 2005. It argued that the grievor?s physical and mental health were in issue and the
summary was needed to disclose the medical a ssistance sought by the grievor and to provide a
complete picture of the grievor?s pre-existing condition. In ordering disclosure of the grievor?s
OHIP
summary, the Vice-Chair wrote as follows:
?I agree with the statement in Re Becker Milk Co. Ltd.,supra at p. 428, regarding
disclosure of medical records:
In ordering the disclosure of medical records, arbitrators must be sensitive to
fact that such records may include personal and confidential information. In
exercising the required discretion, the individual?s interest in the non-
disclosure of personal and confidential medical information must be balanced
with the policy considerations that suggest that disclosure is useful and
necessary.
In this case, I find that the balance favours disclosure. It is clear that not only is the
grievor?s mental and physical health at issue, but causation is also a very significant
issue. The Union alleges that events and harassment at the workplace directly caused the
grievor to become ill and unable to work. Assuming that the grievor is unable to work
due to stress and anxiety, the question of causation remains. Was his situation caused by
events at the workplace for which the Employer is arguably liable, or did it result, in
whole or in part, from a pre-existing condition, such that the Employer, arguably, is not
liable? In these circumstances, the grievor?s pre-existing medical condition is a relevant
subject of inquiry, as is the ongoing treatment due to his claim of future lost earnings, and
the OHIP summary will assist in determining what treatment the grievor has sought.
I cannot agree with the Union?s argument, under the facts of this case, that disclosure
means that the victim is being victimized tw ice. Nor does it mean, in every case, that a
grievor who alleges that the employer?s misconduct caused them to become ill must
disclose their whole medical history. Each cas e depends on its facts. In this case, the
grievor has had a long history of stress and anxiety, including pa nic attacks. It is this
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fact, and its significance to the Employer?s defense and the issues in dispute, that entitles
the Employer to explore the grievor?s medical history through the OHIP summary.
In so ruling, I conclude that the Employer need not rely on the grievor?s recollection of
the physicians he saw over the years, or first se ek the clinical notes of the doctors he has
named. There is no assurance that the grievor?s recollection is complete, whereas the
OHIP summary would be a relia ble indicator. Although the summary may also include
medical treatments unrelated to this case (e.g., a visit to a podiatrist), it may also include
information which is highly relevant to the Em ployer?s defense in this case.
The issue for determination as framed by c ounsel is whether the Employer is entitled to
an order directing Mr. Hyland to produce documentation about his entire medical history from
June 1, 2004. In dealing with this issue, it is n ecessary to balance Mr. Hyland?s interest in not
disclosing personal and confidential medical info rmation with the Employer?s interest in
obtaining disclosure of arguably relevant medical information that is necessary to defend the
grievances. After consideri ng the submissions of counsel, it is my conclusion that the
Employer?s request is too invasive and that it is not warranted having regard to the facts and the
issues in this case.
Mr. Hyland again complains that the Employer, albeit at a different institution, has failed
to accommodate properly his asthmatic condition. He claims that he continues to encounter
cigarette smoke, and perhaps other allergens, in the workplace and that these exposures have
caused adverse reactions resulting in absences from work. Therefore, the issues in this
proceeding appear to focus primarily on Mr. Hy land?s exposure to cigarette smoke in the
workplace and stress arising from these circumstances.
As Vice-Chair Abramsky noted in Re OPSEU (Richard),supra, each case depends on its
own facts and it is not always the case that a grievor will be required to disclose his or her entire
medical history upon alleging that the employer?s misconduct caused illness. I agree with the
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submission that the circumstances of this ca se are significantly different from those in Re
OPSEU (Richard),supra. In contrast to the grievor in that case, Mr. Hyland is not making a
generalized claim which places his entire medical hi story in issue. There is not an issue about
causation like there was in that case. The Employer has not identified any defense which
demonstrates that it is necessary for the Employer to have access to documentation relating to
Mr. Hyland?s other medical
issues.
Accordingly, I find that counsel for the Union?s proposal is preferable in the
circumstances. I therefore direct Mr. Hyland to provide the Employer with a medical report
from his family doctor which responds to the ques tions counsel indicated at the hearing that he
would ask the doctor. As counsel for the Union offered at the hearing, he shall review these
questions with counsel for the Employer, and consider any suggestions he may have, before
sending the doctor the request for a medical report. The general purpose of the medical report
will be to address issues rela ting to Mr. Hyland?s asthmatic condition, his absences from work
and any stress related problems that he has reported and the cause of such problems.
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Dated at Toronto, this 20 day of April, 2006.
Ken Petryshen ? Vice-Chair