HomeMy WebLinkAbout2005-2261.McNaughton.06-02-01
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Crown Employees Commission de ~
~- -- Grievance Settlement reglement des griefs
Board des employes de la
Couronne
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Suite 600 Bureau 600 Ontario
180 Dundas 81. 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 Telee. : (416) 326-1396
GSB# 2005-2261
UNION# OLB538/05
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IN TtlE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN p-
Ontario Liquor Boards Employees' Union '-"') rj 0 'C~.
15 ~ -0-- '-"
(McNaughton) {) L ...) ~c _ ...)
~;~. Union
- and -
The Crown in Right of Ontario
(Liquor Control Board of Ontario) Employer
BEFORE Nimal V. Dissanayake Vice-Chair
FOR THE UNION Ernest A. Schirru
Koskie Minsky LLP
Barristers & Solicitors
FOR THE EMPLOYER Alison E. Renton
Counsel
Liquor Control Board of Ontario
HEARING January 18, 2006.
~
~ J
2
Decision
This decision pertains to a discharge grievance dated
October 4, 2005 filed by Ms. Melinda McNaughton. The case
was argued on the basis of an Agreed Statement of Fact and
no viva voce evidence was called. The agreed facts are as
follows.
AGREED STATEMENT OF FACTS
The Employer and the Union (hereinafter "The Parties")
agree that the following agreed statement of facts is
being entered into this matter without prejudice and
precedent to any other matter between the Parties and
may be supplemented by either Party by viva voce
evidence.
1. The Grievor commenced employment as a casual
warehouse worker at the London Retail Service
Centre in 1999. On April 25, 2005 she was promoted
to a full time warehouse worker 3 at the London
Retail Service Centre.
2 . Effective March 25, 2003, the Grievor was
terminated from her position. A Grievance was
filed and the Grievor claimed that she had an
alcohol addiction which was accepted by the
,
Employer. Minutes of Settlement were entered into
dated April 11, 2003 (hereinafter "the 2003
Minutes" ) which set out various treatment
requirements by which the Grievor had to follow. A
copy of the 2003 Minutes are appended hereto as
Appendix "A".
1 .
3
--
3 . Pursuant to the 2003 Minutes, the Grievor was
reinstated.
4. By letter dated September 12, 2003, the Grievor was
terminated from her position. A Grievance was filed
and was referred to the GSB as the subject matter
of GSB # 2071/03. Again, the Grievor claimed that
she had an alcohol addiction which was accepted by
the employer. Minutes of Settlement were entered
into dated February/March 2004 (hereinafter "the
2004 Minutes" ) which set out various requirements,
and addiction treatments for the Grievor to follow
and the Grievor was reinstated. The Grievor was
represented by union counsel during this
proceeding. A copy of the 2004 Minutes are
appended hereto as Appendix "B".
5 . On Tuesday, September 13, 2005, the Grievor was
absent from the workplace. She returned to work
September 14, 2005. She did not bring a doctor's
note to substantiate her absence within three (3 )
calendar days as required by paragraph 10 of the
2004 Minutes. The Grievor otherwise maintained an
attendance rate within the parameters set out in
paragraph 10 of the 2004 Minutes.
6. The Grievor was issu~d a letter dated September 20,
2005 for not bringing in a doctor's note within
three (3) calendar days and a meeting was scheduled
for September 28, 2005. A copy of the September
20, 2005 letter is appended hereto as Appendix "C".
7 . The grievor attended the September 28, 2005 meeting
along with her union representatives, Steve
Saysell, Joe Hollyman and Jim McNelly. Robert Cote
and Mark Wagner attended the meeting as the
Employer's representatives. At the meeting, and
for the first time, the Grievor proyided a doctor's
, .
4
note dated September 13, 2005 that is appended
hereto as Appendix "D". The Grievor stated in the
meeting that on September 13, 2005 she called her
doctor's office for an appointment but was not able
to obtain one. The Grievor did not obtain an
appointment with her doctor until September 23,
2005. During this appointment, she asked her
doctor to back date the note to September 13, 2005,
which the Grievor disclosed to the Employer during
the September 28 meeting. At the meeting, the
Grievor stated that she knew and understood the
terms of the 2004 Minutes. At the meeting, the
Grievor did not relate her absence or her failure
to bring in a doctor's note due to an alcohol
addiction. There is no issue with respect to
whether or not the Grievor was actually ill on the
day in question.
8. By letter dated October 3, 2005, the Grievor was
terminated. A copy of this termination letter is
appended hereto as Appendix "E".
8a. A stage 3 grievance, dated October 4, 2005 was
filed. A copy of the grievance is appended hereto
as Appendix "F".
9 . Paragraph 11 of the 2004 Minutes state:
The Parties agree that failure to meet any of the
requirements of the agreement for the two (2) year
period following the Grievor's reinstatement shall
result in the Grievor's termination without the
right to redress through the grievance and/or
arbitration process except to establish the
veracity of the facts upon whi ch the Employer
relied
10. Paragraph 12 of the 2004 Minutes states:
,
5
---
The Parties agree that an arbitrator's jurisdiction
shall be limited solely to determining the facts
upon which 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. Article 12.4 of the Collective Agreement states:
After five (5) days absence caused by sickness or
injury, no leave with pay shall be allowed unless a
certificate of a legally qualified medical
practitioner is' forwarded to the Employer
certifying as to the nature of the sickness and
that the employee is unable to attend to his/her
official duties. Notwi thstanding this provision,
the Employer may require an employee to submit the
certificate required hereunder in respect of a
period of absence of less than five (5) days.
12. The Parties put to the Arbitrator the following
question:
a) Should the Grievor's termination be upheld. for
breaching the 2004 Minutes?
13. The Union puts to the Arbitrator the following
questions:
Do paras. 10, 11, 12 of the 2004 Minutes violate
the HRC?
If yes, are the 2004 Minutes void and/or
unenforceable to the extent they violate the HRC?
ALL OF WHICH IS SUBMITTED, THIS 18TH DAY OF JANUARY,
2006 in London, Ontario
(Attachments omitted)
.
6
The 2004 Minutes of Settlement under which the grievor
had been reinstated, referred to by the parties as "the
last chance agreement" (hereinafter "LeA") , included
paragraphs 11 and 12 set out in the agreed facts as well as
paragraph 10 which reads:
10. The Grievor agreed that upon her return to active
work, she shall maintain an attendance rate,
exclusive of vacation, pre-approved absences, or
serious illness or serious accident, as follows:
For the first six ( 6) months following
reinstatement, she shall miss no more than three
(3) shifts. For the following six ( 6 ) months, she
shall miss no more than five (5) shifts. For the
year following the two (2) six ( 6 ) month periods,
she shall miss no more than ten (10) shifts. The
Grievor shall provide documentation substantiating
such absence within three (3) calendar days upon
her return to work. Further, the Grievor agrees
that, without exception, she shall report all
absences and late arrivals in a timely manner, and
specifically not less than fifteen (15) minutes
prior to the beginning of her scheduled shift,
except in situations of serious illness and in
situations as serious accident requiring
hospitalization. The Grievor shall call and speak
in person with a supervisor and in the event she
has left a voice mail message before the
commencement of her shift, she shall call again and
speak in person with a supervisor to confirm the
voice mail message.
(Emphasis added)
The agreed .facts establish that the grievor was absent
on Tuesday September 13, 2005. Documentation
substantiating that absence was provided to the employer
,
7
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only on September 28, 2005. Thus, the union concedes that
the grievor violated that requirement in the LCA.
The parties agree that the grievor suffered from an
alcohol addiction, and that as such she was subject to a
"disability" :within the meaning of s. 5(1) of the Ontario
Human Rights Code, which in part reads:
5. (1) Every person has a right to equal treatment with
respect to employment without discrimination because of
. . . disability.
The union's primary argument is based on s . 5. It
submits that paragraph 10 of the LCA which requires the
grievor to provide documentation substantiating absences
within 3 days upon returning to work as well as paragraphs
11 and 12 which prescribe automatic termination and limit
an arbitrator's jurisdiction do not apply to other
bargaining unit employees. The only reason the grievor was
subjected to those extra-ordinary terms is because of her
disability, i.e. her alcohol addiction. Therefore, the
argument goes, those terms are discriminatory on the
grounds of disability contrary, to s. 5 of the Human Rights
". " Code, and are of no force and effect.
,
8
Union counsel acknowledged that the grievor's absence -
on the day in question or her failure to provide medical
documentation within 3 days for that absence was not
related to her alcohol addiction. However, he submitted
that that was not the relevant issue. The critical fact
was that the grievor would not have been subject to the
requirement in the first place, but for her past history of
absences due to her disability.
Employer counsel reminded the Board of the well
established principle that parties should be held to the
undertakings made in grievance settlements. She stressed
that good labour relations policy requires that the
grievance settlements be strictly enforced. Re Braybrooke
1437/01 (Dissanayake) . She submitted that the grievor had
reaped the benefits of the 2004 Minutes of Settlement,
including being reinstated in her job, and that she was now
seeking to be relieved of the obligations she had
undertaken in return. Union counsel did not dispute the
general principle that grievance settlements must be
strictly enforced. However, he submitted that any term of
settlement that contravened the Human Rights Code is void
and unenforceable. An arbitrator ought not, and is not
.
9
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required by any legal principle, to enforce or uphold a
term in a settlement which contravenes the Code.
I agree with the general principle espoused by the
employer, as well as the exception relied upon by the
union. The case law clearly supports that position. For
example, in Re Labatt Breweries Ontario, (2002) 107 L.A.C.
( 4 th ) 126 (Barrett) at p. 140, the arbitrator states, "I am
strongly In favour of upholding last chance agreements
unless they are in violation of the Human Rights Code." A
well reasoned statement in that regard is contained in Re
-
DeHavilland Inc. (1998) 74 L.A.C. ( 4 th ) 125 (Rayner) at p.
128 as follows:
There is a strong policy reason to honour the terms of
"last chance" agreements as I pointed out in my earlier
award between the parties. Even if there is some
residual power in the arbitrator to modify a discharge
in the face of language similar to paragraph ( 6) , and I
have grave doubts as to whether any such residual power
exists, one must keep in mind the reasons for "never-
never" or "last chance" letters. They permit the
employee to have one final opportunity to keep his job
and they permit both parties, the Company and the
Union, to resolve cases by agreement without resorting
to the CQsts and uncertainty of an adversarial process.
In my op~nion the foremost consideration that should be
in the mind of the arbitrator when asked to consider
such letters should be the integrity of the letter
itself. If these types of agreements are subject to
10
modification except in the most limited - l
of
circumstances, they simply will not be made. As a
result future employees who might have received the
benefit of one of these letters will be denied that
opportunity. Hence the policy of supporting these
letter transcends the case of the individual grievor
who has failed to abide by the terms of the letter.
Naturally, it is always open to a union to prove that
the letter has not been breached, or perhaps to prove
that the letter was a legal nullity from the beginning.
However in the face of paragraph (6) I do not think it
is open to the Union to seek a substitution of penalty
based on compassionate grounds which is the relief that
I think the Union seeks. Even if I could grant such
relief, for the reasons set out above I would not do so
in this case no mater how sorry one feels for the
grievor.
I agree with the union that if the terms of a LCA are
contrary to the Human Rights Code, the fact that the union
and the grievor had agreed to those terms is irrelevant.
This is because the rights under the Code may not be waived
or contracted out of. See, Ontario Human Rights Commission
v. Borough of Etobicoke, [1982] 1 S.C.R. 202 (S.C.C.) ; Re
-
Ontario Human Rights Commission v. Simpsons Sears L t d ._'
[1985] , 23 D.L.R. ( 4 th ) 321 (S.C.C.) .
Therefore, the critical issue for determination is the
issue framed by the union, whether paras: 10, 11 and 12 of
.
11
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the LCA void because they are in violation of the Human
Rights Code.
Employer counsel relied on a number of prior
arbitration awards in which last chance agreements were
upheld as not violating the Human Rights Code. Re Espanola
(Town), (1997) 61 L.A.C. ( 4 th ) 149 (Marcotte) ; Re Kimberly-
Clark Forest Products Inc. , (2003 ) 115 L.A.C. ( 4 th ) 344
(Levinson) ; Re York Region District School Board, (2004)
128 L.A.C. ( 4 th ) 317 (Craven) ; Re Toronto District School
Board, (1999) 79 L.A.C. ( 4 th ) 365 (Knopf) ; Re A.a. Smith
Enterprises Ltd. , (2000) O.L.A.A. No. 573 (Tims) ; and Re
-
Labatt Breweries Ontario, (2002 ) 107 L.A.C. ( 4 th) 126
(Barret t) .
In Re Espanola (Town) , (supra) the LCA provided, inter
alia, that "Should Mr. Howe commence drinking which
interferes with his performance or causes him to miss time,
he shall be dismissed forthwith, and he shall not have the
right to grieve such dismissal, nor shall the union present
a grievance on his behalf". On a review of the evidence,
the arbitrator concluded that the grievor breached the LCA
in that "on two occasions the grievor did drink alcohol
12
which consumption caused him to miss work." The ~
issue was
whether the LCA was contrary to the Human Rights Code. At
p. 170-172, the Board wrote:
Further, we note that the 1990 Letter of Agreement does
not require the grievor to never drink alcohol as a
condition of reinstatement. Rather, it provides for
the grievor not to miss work as a result of consumption
of alcohol. That is, we do not find that in
accommodating the grievor's handicap, the Employer
imposed a standard that is higher than applied to other
employees. The parties agreed that as a condition of
reinstatement, the grievor was to be absent no more
than the average absenteeism in his department. In Re
Sault Ste. Marie (Joyce) supra, the arbitrator, as one
condition of reinstatement, directed that the grievor,
who suffered from alcoholism, was to maintain a level
of attendance at work which Uduring the two-year period
must be no worse that the average for employees in his
department." In Re Sault Ste Marie (Hinnegan) the
arbitrator states at pp. 13-4: ureasonable attendance
is normally measured by the employee's level of
attendance compared with the average for other
employees in his department over a reasonable period of
time." In the opinion of Judge Steele at p. 2 [p. 162
O.A.C. ] of his decision in O.P.S.E.U., supra, a
"failure to meet the average attendance record could be
grounds for dismissal of any employee and was therefore
not discriminatory"; but see Judge MacFarland's
decision in that same case, at p. 4 [p. 163 O.A.C. ]
that this standard was not required of other employees
and thus was not lawful. We prefer the view of
arbitrator Joyce, which view is generally held by
arbitrators as indicated by arbitrator Hinnegan, that a
proper standard to measure reasonable attendance is an
employee's departmental average of absenteeism. In so
finding, we note that the grievor's absenteeism over
13
the course of his employment subsequent to April 30,
1990, was related to his alcoholism on the occasion of
his October 1991 accident. We further note, as was Mr.
Sheppard's undisputed testimony, that excessive
absenteeism was a factor in the Employer's initial
decision to discharge him prior to April, 1990. In the
result, we do not find that the standard of reasonable
attendance as measured by the average rate of
absenteeism in the grievor's department was a higher
standard than imposed on other employees in all the
circumstances of the case before us.
As to whether or not the grievor was subjected to
closer scrutiny than were other employees, we note that
in each of the years following his April 30, 1990
reinstatement, his rate of absenteeism, however
measured, greatly exceeded his department average.
Simply stated, that the Employer tolerated this
circumstance for some three years militates against any
argument of closer scrutiny of the grievor arising from
the 1990 Letter of Agreement.
In the result, and based on all the foregoing, we do
not find that the Employer, in the particular
circumstances of the matter before us, failed to meet
its obligation to accommodate the grievor by way of his
handicap. We find, also, that based on the legitimate
and real health and safety requirements attending the
grievor's work circumstance, that to reinstate the
grievor to the public works department would lead to
undue hardship. We also find that, in regard to the
matter of accommodation, the grievor has failed to
fulfill his obligation to seek out successful treatment
of his treatable handicap condition. We also find that
the requirement in the 1990 Letter of Agreement for the
grievor to not be absent at a rate higher than his
annual departmental average is reasonable and in line
with a recognized arbitral view of that which
14
constitutes a reasonable standard of -.--
attendance in
cases of reinstatement where the issue involves
excessive absenteeism.
(emphasis added)
In Re Kimberly Clark Forest Products Inc. , (supra), the
grievor was subject to a LCA which required him, inter
alia, to abstain from the use of non-prescribed drugs for
36 months and to provide urine samples on an unannounced
basis at the employer's request. The grievor was
discharged pursuant to the LCA. The issue before the
arbitrator was whether the requirements in the LCA breached
constituted bona fide occupational requirements (BFOR) for
purposes of the Human Rights Code. The arbitrator
concluded that they were. At p. 367 he concluded:
[30] To summarize, I conclude that the grievor actively
smoked marijuana contrary to his commitment in the LCA.
I further conclude that the requirement that the
grievor abstain from using non-prescribed drugs for 36
months, the requirement that he submit to drug testing
on an unannounced basis for the same period and the
parties' agreement that discharge will be the
appropriate penalty should the test results indicate
the presence of non-prescribed drugs are BFORs.
-
Consequently, the Code does not prohibit the Company
from relying on the prescribed penalty of discharge in
the LCA and the LCA circumscribes my jurisdiction to
substitute another penalty for the discharge in these
particular circumstances.
(emphasis added)
15
r~,
In Re York Region District School Board, (2004) 128
L.A.C. ( 4 th ) 317 (Craven) the grievor was discharged on the
grounds that he had breached a LCA in several respects. At
p. 324 the arbitrator found as follows:
I am satisfied that in respect at least of his failure
to follow the reporting requirements of February 26,
the grievor was in breach of the "last chance"
agreement. It is not necessary to determine whether
this amounted to a "substantial" breach, because it is
;
abundantly clear that the grievor's failure to attend
at work on February 26 and 27 was a sufficiently
substantial breach of the "last chance" agreement.
Item 3 of the agreement refers to "any unacceptable or
unauthorized absence or lateness." The grievor's
absences on February 26 and 27 were due to his
consumption of alcohol on February 26.
At pp. 327-328, arbitrator Craven considered the issue
to be, whether the grievor's continued absences and his
failure to give timely notice of his absences, caused undue
hardship to the employer:
In my opinion this history demonstrates considerable
effort by the Employer to accommodate the grievor's
disability, to provide opportunities for
rehabilitation, and to motivate the grievor to
undertake and commit to ongoing treatment. Despite
these accommodations, and despite the grievor's
repeated efforts to secure medical treatment and to
draw on the support of AA, there have been frequent
relapses.
16
The Employer led evidence to the - -
effect that the
grievor's absences and in particular his failure to
provide timely notice of his inability to attend at
work, have created difficulties in scheduling and in
arranging for the necessary work to be performed,
especially when high school caretakers have been
detailed to work in elementary schools in anticipation
of the grievor's attendance at work. I find that the
grievor's absences and failures to report have imposed
hardship on the Employer.
There is evidence, therefore, of considerable efforts
on the Employer's part to accommodate the grievor's
disabili ty, and evidence too of efforts by the grievor
to address his alcoholism accompanied by several
relapses. The question remains whether the Employer
has accommodated the grievor to the point of undue
hardship. To put it bluntly, when is enough, enough?
At p. 330, he concluded:
To the extent that the grievor's poor attendance and
failure to comply with reporting requirements were
beyond his control, the Employer was entitled to
terminate the grievor in the absence of a demonstrated
capacity for or clear prognosis of future improvement.
The Employer was obliged to accommodate the grievor's
disability to the point of undue hardship. That point
was reached when, after a lengthy history of
unsuccessful attempts at accommodation, the further
hardship necessarily occasioned by additional
accommodation was not offset by substantial evidence of
a good prospect for future performance.,
For all these reasons, the grievance must be denied.
(emphasis added)
17
- .,
In re A.O. Smith Enterprises Ltd. (Supra) , the
arbitrator noted at p. 6 that the grievor had breached the
LCA in the following manner:
18. There is no dispute between the parties that the
grievor breached the provisions of the October 1999
agreement. He failed to participate in the recommended
after-care program, as required by paragraph 6. He did
not produce a doctor's note for his sick days, contrary
to paragraph 8 of the agreement. Finally, his absence
on March 10, and April 10-18, 2000, exceeded "one
occasion every two months" as set out in paragraph 10
of the agreement. The evidence establishes that the
average rate of absenteeism in the plant is less than
six days per year.
The employer's position is set out at p. 7 as follows:
27 The Company further denies that the terms of the
last chance agreement constitute discrimination
prohibited by the Human Rights Code. In any event,
Counsel suggests that the evidence establishes that the
Company has accommodated the grievor up to the point of
undue hardship. The Company asks me to consider its
ongoing unsuccessful attempts to assist the grievor in
light of what it characterizes as the absence of
rehabilitative potential here, and to deny the
grievance.
The union's position was as follows (p. 7) :
29 The Union argues that the grievor suffers from
alcoholism, a handicap within the meaning of the Human
Rights Code. It acknowledges that the grievor's
. attendance has posed serious problems for the Company
'. - and that the. Company has made significant efforts over
18
the years to accommodate him. The Union's
representative submits, however, that although the
parties entered into the last chance agreement here in
issue in good faith, the terms of such agreement
constitute discrimination prohibited by the Code, and
the agreement is thus void and unenforceable.
30 The Union argues that the agreement discriminates
against the grievor on the basis of handicap in that it
subjects him to "unusual burdens." Specifically, the
Union asserts that the agreement is discriminatory in
requiring that the grievor advise the Company of any
medications he may take, and in requiring that he
maintain the plant average attendance record or face
discharge. Most importantly, the Union submits that
the agreement violates the Code inl denying the grievor
the right under section 48(17) of the Labour Relations
Act, 1995 and Article 8.08 of the collective agreement
to have reviewed the penalty imposed on him by the
Company. The Union further maintains that the Company
failed to accommodate the grievor to the point of undue
hardship, and asks me to conclude that the termination
of the grievor's employment pursuant to the last chance
agreement cannot be upheld.
Following a review of the evidence at p .10 arbitrator
Tirns wrote:
43 While it is for the Company to establish that it
has accommodated the grievor to the point of undue
hardship, its efforts must be viewed in the context of
what Arbitrator Rayner referred to as his
"rehabilitation potential." (See Re O-Pee-Chee
Company, supra) .
44 The grievor returned to work in January 2000
pursuant to the last chance agreement. The evidence is
19
" ~
clear that he resumed drinking shortly after his
return, and that he was in breach of the terms of the
agreement by February 2000.
45 The Union asks that I reinstate the grievor on a
last chance basis, with whatever conditions I view as
appropriate. Neither the Union nor the grievor
suggested anything specific that the Company had failed
to do in fulfilment of its statutory obligations.
46 I am of the view after considering all of the
evidence and the submissions of the parties, that the
grievance must be denied.
47 The grievor failed to comply with the terms of the
last chance agreement, and he and the parties agreed
therein that termination of employment would result.
Even if the provisions of the said agreement offend
section 5 of the Human Rights Code, I must conclude
that such discrimination would be excused in the
present case by section 17 of the Code.
48 It was agreed by the parties that regular
attendance at work is an essential duty of the
grievor's job, and I am of the view that the Company'
has established that it has made efforts to accommodate
the grievor to the point of undue hardship.
(emphasis added)
The union relied on two judicial authorities in support
of its position that the provision of the LCA the grievor
had breached was contrary to the Human Rights Code, and
therefore void.
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20
In Re Ontario Human Rights Commission _-::_----.",
v. Gains Pet
Foods Corp. (1993 ) 16 O.R. (3d) 290 (Ont. Div. Ct. ) The LCA
in question was held to be contrary to the Ontario Human
Rights Code in two ways, one of which is directly relevant
to the instant case. The LCA provided, inter alia, as
follows:
(a) During the next twelve (12) months of your
employment you will be expected to maintain a
level of attendance equal to or better than the
average for the hourly rated employees in the
plant. The plant average will be calculated on a
rolling 12-month basis.
Failure to meet the above requirements at any time will
result in the termination of your employment.
The grievor was terminated for non-compliance with that
undertaking. At p. 291-92, the court wrote:
In cross-examination, Mr. Gerber, director of
operations of the respondent company at all relevant
time s , candidly conceded that but for Ms. Black's
absence from November of 1984 to April of 1985, due to
cancer, the restrictive condition would not have been
imposed upon her. (See transcript of evidence, vol. 5,
p. 674, line 14 to p. 675, line 3.)
It was conceded by the respondents throughout that
cancer constituted a handicap within the meaning of s .
4 (1) of the Ontario Human Rights Code, R.S.O. 1990, c.
H.19(the ~Code")
21
Based upon the clear admission of Mr. Gerber, it is
apparent that irrespective of Ms. Black's prior history
of absenteeism, the proximate if not primary cause of
the restrictive condition in the April 29 letter arose
directly from Ms. Black's absence due to her
disability. While it certainly would have been open to
the respondents to warn Ms. Black, upon her return to
work in April of 1985, that she was required to
maintain a reasonable level of attendance, absent
which, she would be terminated, the imposition of the
restrictive condition was discriminatory, stemming as
it did directly from her absence due to handicap: see
Engell V. Mount Sinai Hospital (1989) , 11 C.H.R.R. D/68
(Ont. Bd. Of Inquiry) ; Glengarry Industries/Chromalox
v. U.S.W.A., Local 6976 (1989) 3 L.A.C. ( 4 th) 326
(On t . ) ; and General Tire Canada Ltd. v. D.R.W., Local
536 (1986) , 26 L.A.C. (3d) 95 ( On t . ) .
Although the respondents submitted that the restrictive
condition amounted to nothing more than a warning, we
do not agree. It was a condition not required of or
imposed upon any other employee and it carried with it
the sanction of immediate termination for non-
compliance.
Indeed, Ms. Black's subsequent failure to live up to
that condition led directly to her termination on
January 6, 2986. The letter of termination, found at
tab 6 of the Appeal Book, leaves little doubt that Ms.
Black's dismissal stemmed in large measure from her
failure to comply with the terms of the restrictive
condition, a condition which we have found to be
discriminatory and in violation of her rights under the
Code.
It should be noted that although the second paragraph
of the termination letter begins with the words "we
agreed at that time (April 29, 1985) that your
22
continued employment with Gaines", the record is clear
that Ms. Black, at that time, simply agreed to do the
best she could. Her acceptance of these conditions was
to that extent qualified. Regardless, even if it could
be said that she agreed to the restrictive condition,
such agreement would be unenforceable: see Ontario
(Human Rights Commission) v. Etobicoke (Borough) ,
[1982] 1 S.C.R. 202, 132 D.L.R. (3d) 14
Thus, we are satisfied that Ms. Black's termination was
both directly and substantially linked to the
imposition of the restrictive condition which we have
found to be discriminatory.
(emphasis added)
In OPSEU v. Ontario (Ministry of Community and Social
Services) [1996] O.J. No. 608 ( On t . Div. Ct. ) , para 4 of
the LeA provided as follows:
4. The Grievor's attendance record will be reviewed
every six months for a period of two years
following the date upon which the Grievor is re-
instated to his employment.
If in any six month period the Grievor fails to meet or
surpass the average attendance record of the
department, he will be subject to dismissal pursuant to
the terms of this agreement.
The grievor failed to meet the average attendance
record of the department for the 6 month period ending
April 27, 1993 and was terminated.
23
} The union's argument there was very similar to the one
made before me:
11 The Union, on behalf of Mr. Blackhall, argues that
this paragraph 4, in particular, is discriminatory in
that Mr. Blackhall is required, by its terms, to
perform to a standard not required of one-half of the
other employees within his department, the departmental
average representing the midpoint with half the
employees above the average and the other half below
it.
MacFarland J. for the majority held:
13 We are of the view that paragraph 4 is
discriminatory because at the very least, it requires
Mr. Blackhall whose absenteeism was known to be caused,
at least in part, by his handicap, to meet a standard
not required of other employees and subjects him to a
review process when other employees similarly situated
are not.
14 The evidence is clear that in 1991 when Mr.
Blackhall was initially terminated he has been absent a
great deal of time due to his obsessive compulsive
disorder and the employer was aware of it. It is also
clear that in imposing paragraph 4 of the settlement
agreement on Mr. Blackhall they did so - at least, in
part, because of his absence due to a handicap within
the meaning of the Code. In so doing, the employer
discriminated against Mr. Blackhall within the meaning
of the case of Re Ontario Human Rights Commission v.
Gains Pet Food (1993) , 16 O.R. (3d) 290 (On. Div. Ct . ) .
The fact that Mr. Blackhall agreed to the condition
does not assist the employer, as such agreement is
unenforceable: Gains Pet Food at p. 292.
24
In the present case, it is important to note the
requirement in the LeA which the grievor failed to comply
with. She was required to provide medical documentation
for her absence on September 13, 2005 within 3 calendar
days upon returning to work. She returned to work on
September 14 th . Therefore, he was required to provide the
documentation no later than September 17th. She did so only
on September 28th . That delay was the basis of her
termination. This is evidenced from the letter of
termination dated October 3, 2005 which in part reads:
I have considered all the information that is available
to me, and have determined that disciplinary action lS
warranted. I note that you entered into Minutes of
Settlement in February 2004, wherein you agreed, In
paragraph 10, to "provide documentation substantiating
such absence within three (3) calendar days upon your
return to work" and were warned, in paragraph 11, that
failure to meet any of the requirements of the
agreement for a two (2) year period shall result in
automatic termination. Because you failed to provide
the medical documentation for your September 13, 2005
absence in accordance with paragraph 10, your
employment is terminated based upon your breach of
paragraph 11 of the Minutes of Settlement.
On a review of the authorities relied upon by the
parties, the appropriate approach in cases of this nature
is as follows:
25
~.
(1 ) First, it must be determined whether the grievor
breached the standard or requirement in the LCA as
alleged by the employer.
(2) Second, it must be determined whether or not the
LCA subjected the grievor to a standard or
requirement which is higher or more onerous than
that imposed on other employees.
(3 ) Third, if the answer is in the affirmative, I must
determine whether the higher standard or requirement
was imposed on the grievor, in whole or in part,
because of her disability. If the answer is "yes",
the standard or requirement is discriminatory and
violates the Human Rights Code.
(4) Finally, in the event that the standard or
requirement is found to be discriminatory, I must
proceed to consider whether or not that standard or
requirement is nevertheless valid and enforceable
because it constitutes a bona fide occupational
requirement (BFOR) and/or because the requirement
represents the point of undue hardship for the
employer.
26
The decision in Re Toronto District School Board
(supra) relied upon by the employer is a good illustration
of this approach.
At pp. 383-384, arbitrator Knopf wrote:
Therefore, on the narrow question of whether there was
just cause to discharge, the Last Chance Agreement
directs in paragraph 8 that any breach of conditions of
the agreement would be deemed to be for just cause.
These parties agreed in submissions before me that the
grievor has breached conditions of the Agreement.
Therefore, on the basis of the agreed facts and giving
full respect to the voluntarily executed terms of the
Last Chance Agreement, it must be concluded that just
cause for discharge has been proven in this case. But
this does not end the matter. The Union has argued
that the Agreement, in itself, is a violation of the
Human rights Code in that it sets up discriminatory
conditions against the grievor on the basis of her
handicap, that is, her addiction to alcohol. The Union
relies on the reasoning in the Fantom Technologies Inc.
case, supra, at pages 246-248 and following:
Counsel relied on two decisions of the Ontario
Divisional Court. The first was Re Ontario Human
rights Commission and Gaines Pet Foods Corp. (1994) , 16
O.R. (3d) 290. In the Gaines case, the complainant had
a restrictive condition imposed on her when she
returned to work after a six-month absence due to a
serious illness. The condition was that she would be
"expected to maintain a level of attendance equal to or
better than the average of the hourly rated employees
in the plant" [at p. 291]. Failure to meet that
instruction would "result in the termination of [her]
employment". The court noted that irrespective of the
complainant's history of absenteeism, which was
extensive, the primary cause of the restrictive
condition arose directly from her disability. As it
transpired, the complainant failed to live up to the
condition and was terminated. The Court held that even
complainant has accepted the condition, "such -
if the
27
agreement would be unenforceable", at p. 292. In so
holding, the Court relied upon the decision of the
Supreme Court of Canada in Ontario ( Human Rights
Commission) v. Etobicoke (Borough) , [1982] 1 S.C.R.
202.
In the Etobicoke case, the Supreme Court had before it
a mandatory retirement clause in a collective
agreement. It was argued that as the parties had
negotiated the condition and that it was based, in
part,- on the demands of the particular occupation, it
ought to be respected as a bargain between the parties.
Mr. Justice McIntyre, for the Court, held that to give
effect to that argument ~would be to permit the parties
to contract out of the provisions of The Ontario Human
Rights Code . . . It is clear from the authorities,
both in Canada and in England, that parties are not
competent to contract themselves out of the provisions
of such enactments and that contracts having such
effect are void, as contrary to public policy" [at p.
213].
The Divisional Court in Gaines [Ontario (Human Rights
Commission v. Gaines 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. Gaines Pet Foods Corp. , 16 O.R. (3d)
290, 44 A.C.W.S. (3d) 758 ] held that the complainant's
termination was both ~directly and substantially linked
to the imposition of the restrictive condition which we
have found to be discriminatory" [at p. 292 ] and
therefore unenforceable. The Court held that the
complainant's rights under the Code were violated,
because in terminating her the company took into
account her six-month absence due to her cancer. The
Court also noted the complainant's lengthy absenteeism
record and held that ~the law is clear that the
prohibited ground of discrimination need not be the
only reason for the action taken, as long as it forms
one of the reasons", at p.293.
The Gaines decision was followed by another panel of
the Ontario Divisional Court in O.P.S.E.U. v. Ontario
(Ministry of Community and Social Services )
(unreported, February 21, 1996, Court File No.
544/95) . In that case the grievor suffered from an
obsessive compulsive disorder, which was a handicap
28
within the meaning of the Code. The grievor had been
dismissed in 1991 because of absenteeism related to his
condition and was reinstated on terms. Paragraph 4 of
the Settlement providedtha t if he failed to meet or
surpass the average attendance record of the department
in any six-month period, he would be subject to
dismissal. In March, 1993, he failed to meet the
average and was dismissed. The holding of the
Divisional Court, and it is particularly relevant to
this case, was that the grievor was required to meet a
standard not required of other employees, and subjected
him to a review process when other employees similarly
si tuated were not. That constituted discrimination on
the basis of disability contrary to the Code. And, as
in Gaines, the Court held that the fact that the
grievor agreed to the condition does not assist the
employer, ~as such agreement is unenforceable".
Arbitrator Knopf concluded as follows:
I am of the opinion that the decision in Gaines, supra,
and in O.P.S.E.U. v. Ontario (Ministry of Community and
Social Services) , supra, decide the issue in this case.
That is, a condition was imposed upon Comaniuk because
of his handicap, which subjected him to a review
process particular to him, and not imposed upon his
fellow employees. And the fact that he agreed to it,
and was advised by his union in doing so, does not
render the Agreement. any less unenforceable, see the
decision of the Supreme Court of Canada in Etobicoke,
supra. The passage in Labatt's, supra, does not state
the law in Ontario, and appears to be contrary to the
ruling in Etobicoke, supra.
Finally, counsel for the Company argued that paragraph
5 ousted entirely the jurisdiction of an arbitrator to
hear this case. That is, if there was a breach of the
Code, then the proper place for Comaniuk to complain is
either in the Ontario Courts or before the Ontario
Human Rights Commission. He could not come to
arbitration because he .agreed, in paragraph 5 of the
Agreement that he would not. I am of the opinion that
the Agreement not to grieve or to resort to the
arbitration process, is not a provision that is
severable from the rest of paragraph 5. Indeed, it is
an essential part of it, and the whole is violative of
29
'.
the Code and unenforceable for the reasons set out
above.
The preliminary objection is dismissed and it is
ordered that Comaniuk be returned to work upon receipt
of this Award. This is not a case for compensation.
(emphasis added)
Having concluded that the requirement of the. LeA
breached by the grievor was discriminatory, however, . the
arbitrator stated that such finding was not the "end of the
matter". She went on to consider the employer's argument
that the LCA term in question constituted an accommodation
to the point of undue hardship. She wrote at pp. 387-388:
Again, the recitals in the Agreement set out a
background of work performance problems and alcohol
abuse in the workplace. This led the parties to the
mutual agreement that the situation could not continue.
This is understandable in any workplace, but
particularly so in the context of a public educational
institution. The evidence discloses that by November
1997 there was a recognition that the grievor's
presence at the work site could not be continued and
should not be resumed unless and until abstinence and
other conditions could be maintained. This was a
"reasonable" response to a difficult situation.
Further, the parties recognized that this response was
taken after "every reasonable effort to accommodate"
the grievor had already been provided. (See paragraph
(iv) of the Agreement. ) To ask that the reasonable
terms and conditions of the Agreement be set aside
after having already made "every reasonable effort to
accommodate", the grievor would be putting the Employer
in a position of undue hardship. It would negate the
efforts made to date and it would render meaningless to
this grievor and all others in her situation the
importance of a last chance agreement.
30
Therefore, I must conclude that the evidence
establishes that the Employer had accommodated this
grievor up to the point of undue hardship at the time
the Agreement was signed. Further, at the time of
termination the Agreement can be seen as an additional
accommodation. To expect any further accommodation
would be putting this employer to undue hardship. The
test is not whether anything else could have been done.
There is always something more that could be done for a
person in distress. There is always the hope that one
more try or one more treatment will turn a situation
around. But the Human Rights Code does not demand that
disabled employees be given every conceivable
opportunity. It demands that the employee be
accommodated to the point of undue hardship by the
employer. The facts here establish that the Employer
has met the burden of proving that level of
accommodation.
(emphasis added)
P-
It is apparent that in Re Toronto District School Board
the LCA provision was upheld, although found to be
discriminatory and contrary to the Code, only because on
the particular evidence the Board concluded that the
employer could not make any further accommodation, without
suffering undue hardship, with regard the grievor's
inability to attend work to an acceptable level.
The same is true of the decision in Re Labatt Breweries
Ontario, (2002) 107 L.A.C. ( 14 th) 126 (Barrett) . There the
~
grievor had a heroin addiction. In a LCA all parties had
31
, ,
J agreed that "the company has fulfilled its duty of
reasonable accommodation under the Human Rights Code and
the union shall not argue for any further accommodation of
Simon by the Company" The union's position is set out at
p. 138:
It is the position of the Union that several provisions
of the last chance agreement discriminate against the
grievor due to his handicap. He has restrictions
placed on him that are not imposed on others.
Paragraph 4 provides that he cannot be under the
influence of drugs while not at work. The testing
provision is not imposed on other employees, and
testing can measure drug use outside of working hours.
Paragraph 7 requires that he maintain the plant average
absenteeism rate, while paragraph 9 takes away his
right to have an arbitrator exercise her jurisdiction
to substitute a lesser penalty than discharge for a
breach.
In the LCA, the grievor had agreed to immediately co-
operate with a company request to provide a blood or urine
sample when requested, for testing for drugs. He was
discharged because he refused to provide a urine sample
when requested.
At pp. 142-143 the arbitrator wrote:
The provision of the last chance agreement that Mr.
Bartolo violated was one that was reasonable and bona
fide in the circumstances, and not discriminatory in
the light of his acknowledged drug addiction and the
obvious requirement that people be drug-free at work.
I do not think it is necessary for me to examine every
clause in the last chance agreement for signs of
32
discrimination arising out of handicap. The one that
was violated was reasonable and bona fide.
At p. 143 she concluded that the employer had
accommodated the grievor to the point of undue hardship:
I find that the Company had accommodated the grievor's
handicap up to the point of undue hardship at the time
it terminated him. It put up with a lengthy discipline
and absenteeism history, it accommodated two four-month
and one seven-month leaves of absence for
rehabilitation programs, the last two of which were
paid for by the Company. On the last two occasions,
his return to work hours were accommodated to meet his
program requirements without loss of pay. And, of
course, there is the very important acknowledgement
that the last accommodation was sufficient.
(emphasis added)
Turning to the other arbitration decisions relied upon
by the employer, in Re Espanola (supra), it was found that
the grievor was not subjected to a higher standard, and
further that he had been accommodated to the point of undue
hardship.
In each of the other decisions relied upon by the
employer, the decision turned on the fact that the
requirement imposed on the grievor was a bona fide
occupational requirement and/or that the employer had
accommodated the grievor to the point of undue hardship.
-
.
33
" ~- -1
Turning to the instant case, the first of the four
steps I have set out above is easy to apply since the
parties agree that the LCA was breached by the grievor.
She was required to provide documentation relating to an
absence within 3 days of her return to work. She failed to
meet the 3 day timeline.
As for the second step, employer counsel argued that
the 3 day time limit was not a requirement peculiar to the
grievor. Reference was made to article 12.4 of the
collective agreement which is set out in the agreed facts.
\
,
(p. 5 supra)
I agree with union counsel that the LCA requirement in
question is very different and more onerous than that
contained in article 12.4. That article is about
entitlement to leave with pay for absences caused by
sickness or injury. It does not impact on the issue of
just cause for discipline and discharge. In any event, for
absences of less than 5 days, it gives the employer a
discretion to require a medical certificate. It does not
require a certificate in all cases of absence due to
sickness, as was the case in the grievor's LeA. Finally,
-
34
article 12.4, unlike the LCA, does not stipulate any time
deadline for production of a medical certificate.
Therefore I conclude that the LCA imposed a higher standard
on the grievor.
Moving on to the next step in the analysis, employer
counsel pointed out that while the grievor's absence on the
day in question was due to a legitimate illness, it had
nothing to do with her disability, i.e. her alcohol
addiction. Her failure to produce medical documentation
with 3 days was not related to her disability either. Thus
she submitted, that the LCA requirement the grievor
breached was not linked to the disability and therefore
could not held to be contrary to the Human Rights Code.
In my view, the fact that the breach itself was not
related to the disability is irrelevant. That is not the
test. The test is whether or not the higher standard was
imposed on the grievor because of her disability. See the
Court decisions in Re Gaines Pet Foods and Re OPSEU
(supra) . To illustrate, assume that a LeA requires that X
be not absent more than 5 days in any calendar month, a
condition not required of other employees. The requirement
-
-
35
/r-' 1 imposed X in attempt to control her absenteeism
} was on an
due to her disability i.e. a drug addiction. X exceeds the
5 day limit following an auto accident. Even though the
breach was caused by an absence unrelated to X's
disability, it would nevertheless be discriminatory because
X would not have been subjected to that 5 day time limit,
but for her disability. The same is true in the present
case. But for her addiction, the grievor would not have
been subject to the requirement she breached. The employer
did not argue otherwise. That is the link that renders it
discriminatory on the grounds of disability. Thus in
Gaines Pet Foods (supra) , the Court reasoned " it is
. . .
apparent that irrespective of Ms. Black's prior history of
absenteeism, the proximate if not primary cause of the
restrictive condition in the April 29 letter arose directly
from Ms. Black's absence due to her disability". In OPSEU
v. Ontario, the Court stated: "We are of the view that
paragraph 4 is discriminatory because at the very least, it
requires Mr. Blackhall whose absenteeism was known to be
caused, at least in part, by his handicap, to meet a
standard not required of other employees and subjects him
to a review process when other employees similarly situated
- are not". The Court observed: "It is also clear that in
~
.
36
imposing paragraph 4 of the settlement agreement on Mr.
Blackhall, they did so - at least in part, because of his
absence due to a handicap within the meaning of the Code.
In so doing, the employer discriminated against Mr.
Blackhall within the meaning of the case of Re Ontario
Human Rights Commission v. Gains Pet Food, (1993 ) 16 O.R.
(3d) 290 (Ont. Div. Ct)".
Based on the legal principles reviewed above, I
conclude that paragraph 10 of the LCA is discriminatory on
the basis of the grievor's disability and offends the Code.
The final issue is whether paragraph 10, although
discriminatory, is nevertheless enforceable on the grounds
that the requirement imposed on the grievor represented the
point of undue hardship on the employer's duty to
accommodate, or that the requirement constituted a BFOR.
As noted, such a result was achieved in cases such as
Toronto District School Board ( supra) on the grounds that
the employer had reached the point of undue hardship in
accommodating the grievor's disability. In the present
case the employer did not make an argument of undue
hardship. This is not surprising because on the particular -
-
37
r-", facts such could have
an argument not succeeded. If the
breach on the part of the grievor had been a failure to
meet the attendance rate imposed on her in paragraph 10,
depending on the totality of the evidence, an argument
could have been made that the ability to meet that rate of
attendance was a reasonable requirement, and that there was
no further accommodation the employer can make to help the
grievor achieve that attendance rate. Similarly, if the
requirement breached caused the employer serious
operational problems, (e.g. : failure to give timely notice
of an absence as in Re York Region District School Board)
(supra) , an undue hardship argument may be made. The
breach by the grievor was not of that nature. The grievor
did produce the required medical substantiation. Her
breach was, she produced it late. There is simply no
evidence that that delay caused the employer any hardship.
S. 17(1) and (2) of the Human Rights Code provides:
s. 17(1) A right of a person under this Act is not
infringed for the reason only that the person is
incapable of performing or fulfilling the
essential duties or requirements attending the
exercise of the right because of handicap.
(2) The Commission, a board of inquiry or a court
shall not find a person incapable unless it
is satisfied that the needs of the person
cannot be accommodated without undue hardship
on the person responsible for accommodating
those needs, considering the cost, outside
~
.
38
sources of funding, if any, and health and
safety requirements, if any.
The failure to produce medical documentation within 3
days has no impact on the grievor's ability to perform the
essential duties of her job. Indeed, there is no
suggestion that the grievor was deficient in relation to
job performance, by way of her ability to regularly attend
work or in any other way. At least there is no suggestion
to the contrary. It is not conceivable (and it was not
argued) that the grievor's failure to adhere to the 3 day
time limit in producing medical substantiation for her
absence on September 13, 2004 caused the employer any
hardship, let alone ~undue hardship".
It follows that unlike in the cases relied upon by the
employer, in the present case there is no legal basis upon
which the requirement imposed on the grievor, which I have
found to be discriminatory, can nevertheless be found to be
enforceable. Therefore the grievor's discharge cannot
stand since it was based on a provision in the LCA which
was contrary to the Human Rights Code. That provision is
void and unenforceable.
-
~
.
39
,/'-- ".
Employer counsel submitted that in the event I find to
that effect, I ought nevertheless impose an appropriate
degree of discipline on the grievor for her breach. In the
circumstances of this case, I have no basis for doing that.
Since the employer is not entitled to rely on the LeA
provision, to justify any discipline, the employer must
establish just cause. The evidence before me does not do
that. I have no evidence that the employer required,
independent of the LCA, that the grievor produce medical
substantiation by exercising its discretion under article
12.4. Even if there was evidence that the grievor was
under such a direction, from the employer, independent of
the LCA, to produce medical substantiation for her absence
on September 13th, 2005 within 3 days of her return to work,
the only facts before me are to the effect that the grievor
represented to the employer that she attempted to get an
appointment with her doctor but could not get one until
September 23, 2005. Employer counsel submitted that the
grievor could have gone to the emergency dept. in a
hospital or to some other medical clinic, rather than wait
for her own physician. However, that issue was not
litigated and I have no evidence in this regard at all.
;
- Were there other options available to the grievor and if
-
40
so, did she have a reasonable explanation for not taking
those options. There is simply no evidence before me upon
which I can find that the grievor was culpable. That is a
matter not addressed by the parties, except by way of
employer counsel's submission.
In the cases where a disabled employee's discharge is
upheld based on a LCA, arbitrators often express their
personal sympathy for the grievor. Arbitrators recognize
that the employee is denied his livelihood because of his
disability, but that it is a necessary result because the
employer cannot, under the law, be required to undertake
any more hardship. In the present case the reverse is
true. The sympathy goes to the employer. It had entered
into the LCA in good faith with a genuine desire to assist
the grievor with regard to her disability. As employer
counsel pointed out, the grievor benefited from that
agreement. No doubt, it would be very frustrating that it
finds itself unable to rely on the deal struck. However,
despite the good faith and. the lack of fault, the Human
Rights Code as interpreted by the Courts must prevail. I
have no discretion but to enforce the law.
- ..
41
[' "
It follows from the foregoing that the grievance must
succeed. The employer is directed to reinstate the grievor
forthwith and to compensate her for all losses that
resulted from her termination. I remain seized in the
event the parties have any dispute in implementing this
decision.
Dated this 1st day of February, 2006 at Toronto, Ontario
J;
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