HomeMy WebLinkAboutP-2016-0449.Courchesne-Godin et al.17-11-30 Decision
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PSGB# P-2016-0449; 2016-0616
IN THE MATTER OF AN ARBITRATION
Under
THE PUBLIC SERVICE OF ONTARIO ACT
Before
THE PUBLIC SERVICE GRIEVANCE BOARD
BETWEEN
Courchesne-Godin et al Complainant
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The Crown in Right of Ontario
(Ministry of Children and Youth Services) Employer
BEFORE Kathleen G. O’Neil Chair
FOR THE
COMPLAINANTS
G. Courchesne-Godin, L. Hunter, K.
Turner
FOR THE EMPLOYER Peter Dailleboust
Treasury Board Secretariat
Legal Services Branch
Senior Counsel
HEARING May 8, 2017 with written submissions
concluded on June 8, 2017
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D E C I S I O N
[1] This decision deals with two complaints relating to the pay of Ginette
Courchesne-Godin, Lorri Hunter, Candace Prong and Kim Turner, all
Administrative Assistants in Youth Centres. They claim that, since 2016, their
pay has improperly excluded payments made to their unionized counterparts, in
breach of their terms and conditions of employment, including equal pay for
equal work. In the alternative, they claim pay adjustments in line with managers
who are also excluded from collective bargaining. As well, they are of the view
that their positions are not properly classified. The employer is of the view that
they have been properly paid.
Factual Context
[2] As assistants to senior administrators in youth correctional centres, the
complainants are excluded from collective bargaining due to the confidential
nature of their duties in relation to labour relations and other matters.
Nonetheless, certain elements of their pay have traditionally been linked to that
of unionized staff represented in collective bargaining by the Ontario Public
Service Employees Union (OPSEU), while other aspects have been linked to that
of the Management Compensation Group (MCP), which covers excluded
managerial employees. The complainants have come to see their situation as
being shunted back and forth between the two groups, creating a negative
impact on their compensation and benefits.
[3] In referring to public servants such as the complainants, terms such as “OPSEU
parallel class” or the “Excluded Category” have often been used, and are used in
this decision. As a recent source of the linkage of their pay to OPSEU rates, the
complainants refer to a memo dated March 13, 2014, which reads in most
relevant part as follows:
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The salary ranges for employees in Excluded Category classes will be
those set out in the attached salary schedules effective April 1, 2014, and
employees in these classes will receive corresponding across-the-board
(ATB) salary increases effective the same date.
Going forward, Excluded Category salary ranges in the attached salary
schedules will be adjusted by a corresponding amount simultaneous
with every Ontario Public Service Employees Union (OPSEU) salary
range and salary adjustment after April 1, 2014, effective the same
date when OPSEU salary range and salary adjustments come into effect.
[emphasis added]
This memo reflects the contents of a Management Board of Cabinet Directive for
Determination of Salary Range, Wage Ranges and Remuneration, Excluded
Category 33-43 dated January 27, 2014, but with slightly different wording.
[4] Basic to the complainants’ case is the claim that they have not been granted the
salary adjustments that their OPSEU colleagues received in 2016, which in their
view, is in breach of the salary directive referred to just above. By contrast, the
employer’s position is that members of the OPSEU bargaining unit received a
lump sum, which does not qualify as a salary range or salary adjustment, and
thus the salary directive was not breached.
[5] The context in which this dispute arises was marked by fiscal restraint policies
which impacted both unionized and non-unionized public servants. For the
unionized employees, collective bargaining lead to a Memorandum of Settlement
between the Crown and OPSEU dated September 22, 2015, which froze wages
for 2015 and 2016, and disallowed progression on the salary grids until the end
of 2017. As part of the settlement, an across-the-Board salary increase of 1.4%
was scheduled for January 1, 2017, but wages and progression on the grid were
frozen for bargaining unit employees, so that the fruits of that increase would not
be realized until 2018. Further, and central to the present complaint, bargaining
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unit employees employed on January 1, 2016, became entitled to a lump sum
payment in the amount of 1.4% of their 2015 earned base salary less statutory
deductions. This is the payment which the complainants see as a salary
adjustment, but the employer sees as a payment separate from salary related to
the other things that OPSEU gave up in that period, including wage increases
and wage progression.
[6] The relevant wording of this Memorandum of Settlement is set out as Appendix
B. The employer relies on the fact that there are provisions related to salary, but
they are set out in a distinct section from the provisions as to the lump sum
payment, which is further defined as not affecting an employee’s “base salary for
any purpose whatsoever.” The complainants rely on the fact that the lump sum
is calculated according to each individual’s salary, to support their argument that
it should be considered a salary adjustment.
[7] The employer notes that although the excluded group did not receive the lump
sum, they were eligible to move on the grid at a time when bargaining unit
employees were frozen. Although this did not benefit the complainants
individually, as they were at the top of their salary grids, it did benefit other
members of the parallel classes.
[8] As for the non-unionized group, Secretary of Cabinet Steve Orsini issued a
memorandum on December 15, 2015 addressed to “All OPS Managers and Non-
Bargaining Specialists” on the subject of changes to Non-Bargaining
Compensation for 2015-2016. The text of the memo acknowledges that since
2012, bargaining outcomes with the larger public sector unions had included four
years of 0% increases and that salary ranges for managers and non-bargaining
staff had been frozen since 2009, with a “hard freeze” on earnings at the 2011-12
levels, along with adjustments to benefits. The memo goes on to refer to
compensation changes for 2015-16, which were summarized as follows:
- Ensure earnings do not fall below 2011-2012 levels;
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- Provide a one time in-range movement for employees who are within the
salary range for their position effective April 1, 2015;
- Provide an increase to salaries of 1.4% for those who are within the
salary range for the position, effective January 1, 2016;
- Provide paramedical coverage of $750 per employee, as well as for each
employee's eligible dependents, effective January 1, 2016.
This memo, which was not sent to the complainants and is not an official pay
directive, went on to indicate that more information on these changes would be
shared in the near future. The employer’s position is that the wage provisions in
the memo were not applicable to the complainants, as they are not managers
covered by the provisions of the MCP.
[9] On March 14 and June 15, 2016, the complainants filed these complaints.
Statutory provisions and Case Law
[10] Relevant provisions of the Public Service of Ontario Act (PSOA), Regulation
378/07, the Pay Equity Act, and the Employment Standards Act, as well as case
law referred to in this decision are attached as Appendices for ease of reference.
The Preliminary Objection
[11] The Employer made a two-part preliminary objection asking that these
complaints be dismissed at the outset, without a hearing on the merits. The first
part of the employer's preliminary objection was to the effect that the complaint
was filed too late. Regulation 378/07 pursuant to the PSOA requires that a
complaint be filed within 14 days of the time the complainant became aware of
the working condition or term of employment in issue. The first complaint was
referred to the Deputy Minister on March 14, 2016, some 90 days after the
changes to the MCP ranges were announced on December 15, 2015. Similarly,
the one-time payment for OPSEU members contained in the Memorandum of
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Settlement was communicated broadly on October 30, 2015. The employer’s
position is that the complaints are well out of time in respect of the timing of the
announcements for each of the groups to which the complainants compare
themselves. In light of the prevailing case law of the Board to the effect that
there is no authority to extend these time limits, the employer asks that the
complaints be dismissed. See, among many others, the Board’s decision in
Hasted/BerezowskyOntario (Community Safety and Correctional Services),
CanLII 7473 (ON PSGB) Jan 18, 2016 (Nairn).
[12] The second prong of the preliminary objection is that the remedy requested by
the complainants, i.e. to be paid the one-time lump sum payment received by
members of the OPSEU bargaining unit in 2016, is outside of the jurisdiction of
the PSGB to order. This is put in the context that the complainants have not
identified a term and condition of employment that exists and applies to them that
has not been applied correctly, in that the payments that they request are not
part of their contractual terms, in the employer’s view.
[13] Specifically, the employer submits that the salary provision applicable to the
parallel class employees such as the complainants is that the schedules will be
adjusted by a corresponding amount simultaneous with every OPSEU salary
range and salary adjustment, but there is no pay provision applicable to them
providing for the payment of a one-time lump sum. As noted, it is the employer's
position that the lump sum payment sought by the complainants is neither a
salary range adjustment nor a salary adjustment. As such, the Employer's
submission is that the complainants have not identified an applicable term or
condition of employment that the Board could enforce.
[14] The employer relies on the Board's decision in Hugh MacDonald et al v Ontario
(Community Safety and Correctional Services), 2014 CanLII 76836 (ON PSGB),
(O'Neil). In that case the Board was asked to remedy salary compression with
Correctional Officers by reinstating a minimum 3% differential between the top
level correctional officer salary and the bottom level Operational Manager salary.
Counsel argues that this is analogous to the complainants' request in the current
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case for the one-time lump sum payment that bargaining unit employees
received, which the employer characterized as a signing bonus.
[15] The Board found in the MacDonald decision that there was "no evidence of any
policy, legislation, practice or other term or condition of employment that was in
force at the time of the complaints which provides for the complainants to be paid
in the manner they seek," and dismissed the complaint. The Board is invited to
find, as it did in that case, that to award the remedy being requested would be
tantamount to setting a new term or condition of employment which is beyond the
Board's remedial jurisdiction.
[16] The complainants took a different view of the matter, emphasizing that the
timeliness requirements in the regulation start from the time the complainants
became aware of the situation which they say is a breach of their terms and
conditions of employment. The complainants note that their first Notice of
Proposal to File a Complaint was filed on March 14, 2016, fewer than 14 days
after they learned of the 1.4% lump sum payment to OPSEU members and the
1.4% in-range salary adjustment for OPS managers and non-bargaining
specialists.
[17] As well, the complainants see their complaint as timely as a continuing one, in
that there are repeated or recurring instances of improper pay, any one of which
may be regarded as starting the clock anew for the purposes of determining
whether a grievance is timely. As such, the Complainants argue that the
complaint was timely at the time it was filed, as a continuing pay complaint is
timely with each passing pay period in which a correction is not made. In respect
of the timeliness point, they rely on the following cases: Hasted v Ontario
(Community Safety and Correctional Services), 2016 CanLII 7473 (ON PSGB)
(Nairn), Laird v. Ontario (Ministry of Community Safety and Correctional
Services), 2005 CanLII 53192 (ON PSGB) (O’Neil), Mroz v. Ontario (Ministry of
Community Safety and Correctional Services), 2012 CanLII 17222 (ON PSGB)
(O’Neil).
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[18] As to the second prong of the employer’s objection, the complainants note that it
relies on the employer’s characterization of the payment made to OPSEU
members as akin to a ratification allowance, rather than as a salary range or
salary adjustment. As the Complainants assert that the payment is a salary range
or salary adjustment, they object to a finding on the point, without evidence, on a
preliminary motion. Further, they have put in issue statutory provisions
concerning equal pay.
[19] The Board ruled on March 9, 2017 that the matter would proceed on the merits,
as a continuing pay grievance, and that there were potential remedies within the
Board’s jurisdiction if the complainants were successful on the merits.
[20] In any event, the complainants’ assertion that they became aware of the
circumstances of which they complain less than 14 days before they filed the
complaint was not disputed, so that the requirements of Regulation 378/07, s.
8(1) were complied with. As emphasized in the Board’s decision in
Hasted/Berezo wsky, cited above, that portion of the regulation is reasonably
interpreted to mean that the time limits run from the date that a complainant
becomes aware of circumstances giving rise to the complaint, rather than the
mere existence of the working condition or term of employment which they say
has been breached.
[21] As well, both the salary policy put in issue and the provisions of statute
referenced by the complainants constitute applicable terms and conditions of
employment which the Board is entitled to enforce in the event they are found to
have been breached.
The issues on the merits
[22] The general issue raised by the facts of this case is whether the complainants
are being paid in accordance with their terms and conditions of employment. The
complainants’ case is based on their belief that they are not being given the
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benefit of the applicable terms and conditions of employment, and that they are
being treated unfairly in comparison to both their unionized and managerial
colleagues. It is convenient to deal with their claim in three parts. The first is their
assertion that the pay directives or policies that should apply to them were not
applied to them. The second is the claim that the employer’s treatment of them
has not provided them with equal pay for equal work. This is, in essence, a claim
of breach of statutes which are also part of the complainants’ terms and
conditions of employment. Finally, the complainants are of the view that they are
not classified correctly given the extent of their duties, particularly in regards to
the confidential nature of much of their work, and their view that some of their job
descriptions are out of date.
[23] It is the employer’s position that the complainants’ terms and conditions of
employment have been complied with, and that they are distinct from both the
OPSEU terms and conditions found in their collective agreement, and from those
of the managers covered by the MCP provisions. As counsel, put it, the pay
provisions for the complainants do not go “lock-step” with either OPSEU or the
MCP. Further, the employer denies that there is any breach of its equal pay
obligations. As to the classification of the complainants’ positions, the employer
notes that the Board has no jurisdiction over classification issues.
Pay Directives/Policies
[24] A noted above, the complainants claim the benefit of pay policies related to
increases received by both unionized and non-unionized excluded employees.
Starting with the claim in respect of unionized staff, the issue is whether the
provisions of salary directive 33-43, referred to in paragraph 3 above, apply to
the lump sum payment they seek. In other words: is the lump sum payment
negotiated for OPSEU-represented employees a salary range or salary
adjustment?
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[25] The employer acknowledges that the OPSEU Memorandum of Agreement
contained provisions about salary, but takes the position that the lump sum
payment was not part of the salary provisions. This position is based on the fact
that the parties to the settlement (OPSEU and the government as employer)
chose wording which distinguished salary from the lump sum payment. There
was no change to the salary rates for 2015 and 2016, and no progression on the
salary grid was allowed, which counsel characterized as a “hard freeze” on
salary. The only salary increase was to the salary rates, which were increased
across the board on January 1, 2017, but the members of the bargaining unit will
not get the advantage of the higher rates until the beginning of 2018 given the
freeze on salary movement.
[26] Employer counsel highlights the fact that the parties explicitly agreed that the
lump sums were not to alter base salary for any purpose. Given that agreement,
the employer cautions against a finding that those payments were in fact salary,
which might generate the argument that a significant sum in respect of pension
payments and other salary related items would be due to members of the
bargaining unit, as well as the complainants. The employer’s position is the best
interpretation is that the lump sum was separate from salary, and that it was in
consideration of the 2-year freeze on OPSEU increases and wage progression.
The employer argues that this does not amount to a contractual basis for the
claimed payment to the complainants, relying on a decision of the Grievance
Settlement Board, Association of Management, Administrative and Professional
Crown Employees of Ontario (AMAPCEO) v Ontario (Treasury Board
Secretariat), 2015 CanLII 90154 (ON GSB) (Misra) for the proposition that the
right to a monetary benefit must be derived from a clear contractual provision.
[27] The submissions on behalf of the complainants note that the calculation of the
lump sum payment resulted in highly-individualized payments with significant
variation, across the bargaining unit, in the dollar value of the lump sum, and was
based on individual salary rates. Further, it does not resemble a signing bonus,
or other one time payment on the conclusion of a collective agreement, as it is
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not a fixed amount, but individualized according to salary. As well, it was not
paid at the time of signing, but in 2016. In the complainants’ view, this is not the
way the employer traditionally does lump sum payments. The complainants
argue they should be treated in the same way as their OPSEU colleagues, since
the employer has not provided the parallel class with the compensation changes
paid to their managers.
[28] In deciding which theory of the case is preferable, the Board has reference to the
well-established approach to the interpretation of contracts, which includes giving
the words their plain and ordinary meaning, in the context of the whole contract,
unless there is evidence that the words were intended to have a different or
special meaning. The contractual term in question here is Directive 33-43, which
reads in most relevant part as follows:
Excluded Category salary ranges in the attached salary schedules will be
adjusted by a corresponding amount simultaneous with every Ontario
Public Service Employees Union (OPSEU) salary range and salary
adjustment after April 1, 2014, effective the same date when OPSEU
salary range and salary adjustments come into effect. [emphasis added]
[29] This language provides adjustments to salary ranges only, and in an amount
corresponding to adjustments to OPSEU salary ranges and salary adjustments.
The key controversy stems from the meaning of the word salary. The ordinary,
dictionary meaning of the word “salary” is “a fixed regular payment made by an
employer to an employee” (according to the Canadian Oxford Dictionary, 2001).
The lump sum payment negotiated for OPSEU employees was not a regular
payment, as it was paid on one occasion only. Thus, on the basis of the ordinary
meaning of salary, the 2016 lump sum does not appear to be salary.
[30] The complainants note that the lump sum was calculated from salary, and argue
that as a basis for a finding that it ought to be interpreted as a salary adjustment.
This argument is effectively countered by the language of the OPSEU
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memorandum of settlement which clearly distinguished the lump sum payment
from salary. It is significant that the parties chose to label a section of their
Memorandum of Agreement “Salary”, but the lump sum payment does not
appear in the section of the memorandum related to salary. In the same vein,
the parties added the clarification to the portion of the memorandum related to
the lump sum, “This lump sum payment shall not alter an employee’s earned
base salary for any purpose.” If the lump sum did not alter salary for any
purpose, it is difficult to find that it was a salary adjustment. Further, the wording
related to the lump sum payment did not form part of the collective agreement,
which one would expect for something as fundamental to a collective agreement
as salary.
[31] As well, the usual meaning of a “lump sum” is, in the context of employment, a
single sum of money paid at one-time, as in the Canadian Oxford Dictionary’s
definition “money paid down at once (as opposed to instalment)”. This is
consistent with the wording of the memorandum which provides for the one-time
lump sum in question, as follows:
All OPSEU employees as of January 1, 2016 including employees on
approved leaves of absences and employees temporarily assigned to a
position out of the bargaining unit, shall be entitled to a one-time lump sum
payment equal to 1.4% of earned base salary less statutory deductions. The
determination of earned base salary shall be calculated based on payment of
wages earned for regular hours worked in the 2015 calendar year in an
OPSEU-represented position (including pay in lieu of vacation leave where
applicable), and payment for approved leaves as covered by the Collective
Agreement in the 2015 calendar year while assigned to an OPSEU-
represented position. This lump sum payment shall not alter an employee’s
earned base salary for any purpose.
[32] Given the plain meaning of the specific wording used in the Memorandum of
Settlement, it is clear that the lump sum payment was not intended as a salary
range or salary adjustment. Directive 33-43 only promises employees in the
excluded OPSEU parallel classes salary range or salary adjustments, which the
lump sum payments were not. In these circumstances, the Board finds that the
employer did not breach Directive 33-43 in not paying the complainants the lump
sum paid to their OPSEU colleagues.
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[33] The complainants also made reference to past practice, to the effect that
compensation and salary adjustments had always been the same as OPSEU’s,
until 2011, in support of their contention that it should be the same for the lump
sum as well. Further, they note that in 2013, OPSEU received an increase,
which they also received, but belatedly, and with no retroactivity. Because of
periods when the OPSEU classifications were paid more, the complainants note
that their unionized colleagues receive more for various benefits based on salary,
and pension contributions as well, creating a long-term negative impact on the
complainants.
[34] Past practice can be sufficient to establish a term or condition of employment if
sufficiently clear in its application and scope. However, I do not find that the
evidence that compensation provisions for the excluded category followed those
of OPSEU prior to 2011 sufficient to support a finding that the complainants are
entitled to the lump sum negotiated with OPSEU in 2015, particularly in light of
other evidence that other aspects of the complainants’ compensation has not
followed OPSEU, such as for sick leave and benefits. As to the lack of
retroactivity in 2013, there is insufficient evidence before the Board to establish
that the excluded category was entitled to retroactivity in that year, which pre-
dated the salary directive in evidence.
[35] The complainants also submitted at one point that the freezing of the
complainants’ salary along with those of the MCP in 2011 breached Salary
Director 33-43, in light of the past practice. They see the Directive as setting out
and validating what was past practice. Given that the Directive clearly speaks to
2014 and the future, this is not a sufficient basis to apply it to the years 2011 to
2013.
[36] In the alternative, the complainants seek the entitlements recognized for the
MCP and excluded group in the December 15, 2015 memo from Secretary of
Cabinet Orsini referred to above. This memo is addressed to Managers and
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Non-Bargaining Specialists and was not sent to the complainants as might be
expected if it applied to them. The complainants have seen their management
colleagues receive pay for performance, as well as lump sums, that they did not
receive, even during the period of fiscal restraint. They are of the view that they
are unfairly dealt with in that they receive the negative aspects of compensation
applied to the managerial group, and not the compensating measures, such as
the ones announced in late 2015.
[37] The employer’s position is that the memo announced provisions for the
management compensation plan (MCP), a different compensation group than the
complainants. In the employer’s view, since it is Directive 33-43 that specifically
provides for how salary for the OPSEU parallel classes is determined, the
different provisions summarized in the 2015 memo cannot also apply to them.
Employer counsel submits that the 2015 memo announced the end of the
freezing of pay for the MCP group, but simply does not apply to the distinct
compensation treatment of the OPSEU parallel classes.
[38] The complainants argue that the memo does not state what excluded employees
it refers to, and acknowledge that the memo was not communicated to them at
the time. Nonetheless, it included a reference to coverage for paramedical
expenses, which was extended to the complainants. Noting that their benefits,
sick pay and severance provisions are those contained in the MCP package, the
complainants submit that it is prejudicial to treat them differently for salary than
for benefits.
[39] Having considered all the evidence and argument submitted, the Board finds that
the MCP provisions related to salary have not been shown to apply to the
complainants. In any event, each of the complainants was at the top of her
salary grid, so that the “in-range” increases would not have provided a benefit to
them. As to the claim to the provision that compensation would not fall below the
levels of 2011-12, that provision has been discussed most recently in the Board’s
decision in Rotondo v Ontario (Community and Social Services), 2017 CanLII
39681 (ON PSGB) concerning the detailed policy provisions which were
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summarized in the very generally worded memo. It can be seen that it referred
to adjustments related to the withdrawal of pay for performance, something which
never applied to the complainants. Further, even if the memo had applied to the
complainants, the evidence did not establish that the complainants’ earnings fell
below their 2011-12 levels.
Equal Pay
[40] In their second complaint, and in light of the fact that their group is predominately
female, the complainants claim equal pay for equal work, as compared to their
OPSEU colleagues, and a pay equity review.
[41] Starting with the complainants’ claim to equal pay for equal work, that is a term
found in the Employment Standards Act (ESA). Although the term in its ordinary
usage might suggest that all employees doing the same work are legally required
to be paid the same, the provisions of the ESA only deal with unequal pay as
between male and female employees. The complainants have not identified any
male employee doing the same work as they do who is being paid more than
they, so this part of their complaint cannot be successful.
[42] The complainants also make reference to pay equity, which is a term used in the
Pay Equity Act, which goes further than the ESA to prevent wage discrimination
between male and female work of equal value, rather than males and females
doing the same work. The employer’s position is that the complainants are being
paid in accordance with the provisions of the Pay Equity Act, which provides that
the employer must establish and maintain pay equity in the manner set out in that
legislation.
[43] The Pay Equity Act contains very specific requirements as to how pay equity is
determined, requiring a comparison between male and female dominated job
classes. For pay equity purposes, the comparator is not the OPSEU-
represented jobs who do similar administrative work to that of the complainants.
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Rather, it is a male dominated classification entitled Technician I Construction, as
provided in the applicable pay equity plan.
[44] According to the uncontradicted submissions and documents before the Board,
the complainants, as employees excluded from collective bargaining, were part
of the government’s pay equity plan, described in a document entitled “Ontario
Public Service Pay Equity Plan – Management and Excluded”. This plan,
designed to achieve the legislative requirements, used a job comparison
approach to compare male and female classes, on the basis of the four legislated
factors: skill, effort, responsibility, and working conditions. The analysis included
the generation of a numerical score for each job class sampled, as an average
for each job class, rather than each individual job. Jobs with similar numerical
scores were determined to be of equal or comparable value. These comparisons
provided the basis for adjusting salary rates for female job classes where
necessary to achieve pay equity as prescribed in the Pay Equity Act.
[45] The job category applicable to the complainants listed in the Plan - Office
Administration (Excluded) - was one of the female representative job classes,
and it was compared to the bargaining unit Male Job Class Technician 1
Construction, which was found to be of equal or comparable value. The
comparison was done, as prescribed, between the maximum of the hourly rates,
known as the job rates. The evidence established that the top rate for the
Technician 1 Construction classification effective January 1, 2017 was $26.43.
Both the classifications referred to in argument as applicable to the complainants,
OAG8 and OAG9, had a maximum hourly rate higher than that, being $26.46 and
$27.73, respectively. On that basis, the employer argues that there has been no
failure to maintain pay equity.
[46] The complainants did not challenge the employer’s figures concerning the
maxima up to January 1, 2017, but argue that the maxima were not higher after
2017.
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[47] Further, the complainants argue that the lump sum paid to OPSEU should be
considered part of compensation for purposes of the pay equity comparison,
given the broad definition of compensation in s. 1 of the Pay Equity Act.
[48] The employer answers that the lump sum payment would be included only if
such payments are part of the regular, expected compensation for a job class,
citing the decision of the Pay Equity Hearings Tribunal Group of Employees vs.
Windsor Casino and CAW, 2007 CanLII 62083 (ON PEHT). The complainants
noted that the type of payments dealt with in that decision was different than the
lump sum payments in question here, but did not argue that the case
misinterpreted the legislation as to what should be included in the job rate
comparison.
[49] On the material before the Board, and similar to the findings above that the lump
sum payments were not part of salary, there is an insufficient basis to find that
the lump sum payment in 2016 was part of the regular expected compensation
for OPSEU employees. Both sides in their different ways acknowledged that the
lump sum payments were unusual, and by the terms of the settlement they were
paid on a one-time basis, outside of the collective agreement. These
circumstances favour a finding that the lump sum payments were not part of
regular compensation for OPSEU employees, which would be expected to be
found within the collective agreement itself. In these circumstances, on the
material before me, I do not find that it is a breach of statute or other terms and
conditions of employment to not include the lump sum in the job rate comparison.
[50] Returning to the question of the comparison of the job rates, the evidence did not
establish that the complainants’ job rates were lower than that of the male
comparator class at the time of the complaints or to the end of submissions in
this matter. In these circumstances, there is no basis in the material before the
Board to find that there was a failure to maintain pay equity up until the time of
argument.
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[51] As to the complainants’ claim that the job rates were not higher after 2017, this
aspect of the case was not fully dealt with by the parties, and deals with a future
time. Particularly in light of the proposed review of the complainants’ job
descriptions and classification referenced in the next section, the Board does not
find it appropriate to address any issues in respect of pay beyond the time of final
submissions in the context of this complaint.
[52] The employer also argued that if the Board were to decide that the lump sum
should be included for the purposes of the pay equity comparison, or otherwise
find a pay discrepancy with the male comparator group, any differential would
properly be attributable to the difference in bargaining strength between OPSEU
and the excluded parallel class employees, something explicitly contemplated by
the pay equity legislation. In this respect the employer relied on the decision of
the Pay Equity Hearings Tribunal in Stevenson Memorial Hospital v. Ontario
Public Service Employees Union, Local 360, 2000 CanLII 22419 (ON PEHT), for
the idea that the bargaining strength exception in the Pay Equity Act can apply
between unionized and non-unionized staff. Given the Board’s findings just
above that failure to maintain pay equity was not demonstrated up to the time of
argument, it is not necessary to deal with the employer’s argument about the
application of the bargaining strength exception.
Classification issues
[53] The complainants filed job specifications and postings for the purpose of showing
that they perform duties equivalent to higher rated classifications. Further, the
complainants are of the view that some of their job descriptions are outdated.
The employer objected to the Board’s jurisdiction over this aspect of the
complainants’ evidence, referring to s. 4(2)(2) of Regulation 378/07 which
provides that assignment of a person to a particular classification cannot be the
subject of a complaint to this Board. Notwithstanding the employer’s objection to
the Board’s jurisdiction, the employer agreed to inquire about a discrepancy on
the face of one of the job descriptions tendered, which had a reference to being
in classification OAG8 in one section, and OAG9 in another. The result of the
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inquiry was that the final approved version corrected an arithmetical error, and
showed the final classification as OAG8.
[54] Further, employer counsel wrote in post-hearing submissions that the employer
had ascertained that the job descriptions of the excluded Youth Centre
Administrative Assistants pre-date the establishment of a centralized
organization called the Enterprise Classification Unit (ECU), which
was established to centralize the classification of positions in the OPS. Given that
the job description at issue pre-dated the ECU, and the complainants had raised
the issue of their job descriptions with the Ministry separate from this complaint,
counsel indicated that there was a process ongoing to determine the
classification issues, and that Ministry officials were committed to working with
the complainants in an attempt at resolution. The complainants’ response
included an indication that meetings had not yet occurred in this respect.
[55] It is true that the actual classification of the complainants’ positions is beyond the
jurisdiction of the Board, and thus further consideration of the situation with the
complainants’ job descriptions and classification is beyond the Board’s mandate.
Nonetheless, it is hoped that the parties have already, or will soon complete the
process of ensuring that the complainants’ job descriptions and classification are
accurate for their duties.
[56] In closing it is appropriate to note that much of the complainants’ case arises
from the fact that they do not experience their treatment for pay and benefits as
transparent, fair or consistent. One of them put it that the employer prides itself
on being inclusive, but instead, they are excluded from positive compensation
changes, appearing to be an afterthought, bouncing back and forth between their
unionized and managerial colleagues. As well, they state that when they began
to ask management representatives about their compensation treatment in 2016,
no one could provide an answer as to why they were treated the way they were.
It appears to the Board that there is a great deal of room for improvement in
clarity of communication to members of the parallel classes as to how their
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compensation works and where to find the totality of their terms and conditions of
employment. Although the Board has not found a breach of any of the terms and
conditions of employment in evidence, it is hoped that transparency in regards to
communication with this group will receive renewed attention from the employer
for the future.
[57] For the above-noted reasons, the complaints are hereby dismissed.
Dated at Toronto this 30th day of November, 2017
_______________________
Kathleen G. O’Neil, Chair
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Appendix A – Excerpts from Statutes and regulations
Excerpt from Regulation 378/07 under The Public Service of Ontario Act
Notice of proposal to file a complaint
8. (1) A person who proposes to file a complaint shall give notice of the proposal to
the following person or entity:
1. A complainant who, at the material time, worked in a ministry shall give the notice
to his or her deputy minister.
2. A complainant who, at the material time, worked in a Commission public body
shall give the notice to the chair of the Public Service Commission. O. Reg.
378/07, s. 8 (1).
(2) Subsection (1) does not apply with respect to a complaint under Part V of the Act
(Political Activity) or a complaint under Part VI of the Act (Disclosing and
Investigating Wrongdoing). O. Reg. 378/07, s. 8 (2).
(3) The notice must set out the reasons for the complaint. O. Reg. 378/07, s. 8 (3).
(4) The notice must be given within the following period:
1. For a complaint about dismissal for cause, within 14 days after the complainant
receives notice of the dismissal.
2. For a complaint about a disciplinary measure, within 14 days after the
complainant receives notice of the imposition of the disciplinary measure.
3. For a complaint about a working condition or a term of employment, within 14
days after the complainant becomes aware of the working condition or term of
employment giving rise to the complaint. O. Reg. 378/07, s. 8 (4).
Excerpt from the Employment Standards Act
PART XII
EQUAL PAY FOR EQUAL WORK
Equal pay for equal work
42. (1) No employer shall pay an employee of one sex at a rate of pay less than the rate
paid to an employee of the other sex when,
(a) they perform substantially the same kind of work in the same establishment;
(b) their performance requires substantially the same skill, effort and responsibility;
and
(c) their work is performed under similar working conditions. 2000, c. 41, s. 42 (1).
Exception
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(2) Subsection (1) does not apply when the difference in the rate of pay is made on the
basis of,
(a) a seniority system;
(b) a merit system;
(c) a system that measures earnings by quantity or quality of production; or
(d) any other factor other than sex. 2000, c. 41, s. 42 (2).
Reduction prohibited
(3) No employer shall reduce the rate of pay of an employee in order to comply with
subsection (1). 2000, c. 41, s. 42 (3).
Organizations
(4) No trade union or other organization shall cause or attempt to cause an employer to
contravene subsection (1). 2000, c. 41, s. 42 (4).
Deemed wages
(5) If an employment standards officer finds that an employer has contravened
subsection (1), the officer may determine the amount owing to an employee as a result
of the contravention and that amount shall be deemed to be unpaid wages for that
employee. 2000, c. 41, s. 42 (5).
Excerpt from The Pay Equity Act
Definitions
1 (1) In this Act,
…
compensation” means all payments and benefits paid or provided to or for the benefit of
a person who performs functions that entitle the person to be paid a fixed or
ascertainable amount; (“rétribution”)
…
“job rate” means the highest rate of compensation for a job class; (“taux de catégorie”)
Achievement of pay equity
5.1 (1) For the purposes of this Act, pay equity is achieved in an establishment when
every female job class in the establishment has been compared to a job class or job
classes under the job-to-job method of comparison or the proportional value method of
comparison and any adjustment to the job rate of each female job class that is indicated
by the comparison has been made. 1996, c. 1, Sched. J, s. 2.
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…
Achievement of pay equity
6 (1) For the purposes of this Act, pay equity is achieved under the job-to-job method of
comparison when the job rate for the female job class that is the subject of the
comparison is at least equal to the job rate for a male job class in the same
establishment where the work performed in the two job classes is of equal or
comparable value. R.S.O. 1990, c. P.7, s. 6 (1); 1993, c. 4, s. 4 (1).
…
Idem
(4) Comparisons under the job-to-job method of comparison,
(a) for job classes inside a bargaining unit, shall be made between job classes in the
bargaining unit; and
(b) for job classes outside any bargaining unit, shall be made between job classes
that are outside any bargaining unit. R.S.O. 1990, c. P.7, s. 6 (4); 1993, c. 4,
s. 4 (2).
Idem
(5) If, after applying subsection (4), no male job class is found in which the work
performed is of equal or comparable value to that of the female job class that is the
subject of the comparison, the female job class shall be compared to male job classes
throughout the establishment.
Groups of jobs
(6) An employer may treat job classes that are arranged in a group of jobs as one
female job class if 60 per cent or more of the employees in the group are female.
Idem
(7) An employer shall treat job classes that are arranged in a group of jobs as one
female job class if a review officer or the Hearings Tribunal decides that the group
should be treated as one female job class.
Idem
(8) An employer may, with the agreement of the bargaining agent, if any, for the
employees of the employer, decide to treat job classes that are arranged in a group of
jobs as one female job class.
Job rate, value of work
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(9) Where a group of jobs is being treated as a female job class, the job rate of the
individual job class within the group that has the greatest number of employees is the
job rate for the group and the value of the work performed by that individual job class is
the value of the work performed by the group.
Definition
(10) In this section,
“group of jobs” means a series of job classes that bear a relationship to each other
because of the nature of the work required to perform the work of each job class in
the series and that are organized in successive levels. R.S.O. 1990, c. P.7, s. 6 (5-
10).
Pay equity required
7 (1) Every employer shall establish and maintain compensation practices that provide
for pay equity in every establishment of the employer.
Idem
(2) No employer or bargaining agent shall bargain for or agree to compensation
practices that, if adopted, would cause a contravention of subsection (1). R.S.O. 1990,
c. P.7, s. 7.
…
Exceptions
8 (1) This Act does not apply so as to prevent differences in compensation between a
female job class and a male job class if the employer is able to show that the difference
is the result of,
(a) a formal seniority system that does not discriminate on the basis of gender;
(b) a temporary employee training or development assignment that is equally
available to male and female employees and that leads to career advancement
for those involved in the program;
(c) a merit compensation plan that is based on formal performance ratings and that
has been brought to the attention of the employees and that does not
discriminate on the basis of gender;
(d) the personnel practice known as red-circling, where, based on a gender-neutral
re-evaluation process, the value of a position has been down-graded and the
compensation of the incumbent employee has been frozen or his or her
increases in compensation have been curtailed until the compensation for the
down-graded position is equivalent to or greater than the compensation payable
to the incumbent; or
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(e) a skills shortage that is causing a temporary inflation in compensation because
the employer is encountering difficulties in recruiting employees with the requisite
skills for positions in the job class.
Idem
(2) After pay equity has been achieved in an establishment, this Act does not apply so
as to prevent differences in compensation between a female job class and a male job
class if the employer is able to show that the difference is the result of differences in
bargaining strength.
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Appendix B – Excerpts from OPSEU - OPS settlement
1. SALARY
Amend Article UN 16 as follows:
ARTICLE UN 16 – SALARY
UN 16.1.1 Effective January 1, 2015, the salary rates in effect on December 31, 2014,
shall remain in effect, and are contained in the Salary Schedule set out in the
2013-2014 Collective Agreement.
UN 16.1.2 All salary rates to be increased across the board as follows:
January 2, 2017 – 1.4%
The salary rates in effect on January 1, 2017 for all classifications are
contained in the Salary Schedule attached.
MINIMUM WAGE
Un 16.3 In the event that there is a legislated increase to the minimum wage in
Ontario and a classification that has a minimum hourly rate of pay that falls
within the minimum wage, the minimum hourly rate of pay for that
classification will be adjusted to be equal to the minimum wage, and all
hourly rates of pay in the same classification shall be adjusted to maintain the
dollar difference in hourly rates of pay that existed prior to the adjustment.
2. LUMP SUM PAYMENT
The following language does not form part of the collective agreement.
All OPSEU employees as of January 1, 2016 including employees on approved
leaves of absences and employees temporarily assigned to a position out of the
bargaining unit, shall be entitled to a one-time lump sum payment equal to 1.4% of
earned base salary less statutory deductions. The determination of earned base
salary shall be calculated based on payment of wages earned for regular hours
worked in the 2015 calendar year in an OPSEU-represented position (including
pay in lieu of vacation leave where applicable), and payment for approved leaves
as covered by the Collective Agreement in the 2015 calendar year while assigned
to an OPSEU-represented position. This lump sum payment shall not alter an
employee’s earned base salary for any purpose. [ emphasis added.]
3. SALARY PROGRESSION FREEZE
…
The parties agree that notwithstanding any other article in the collective
agreement, all employees’ salary rates as of January 1, 2016 shall be fixed at
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that rate and no employee shall be entitled to any salary progression from
January 1, 2016 to December 31, 2017. Employees hired or appointed into
positions in the OPSEU bargaining unit during the term of the collective
agreement shall have their salary fixed at the salary rate received upon hire or
appointment and shall not be entitled to any salary progression for the duration of
the collective agreement.
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Appendix C
Case law
Group of Employees vs. Windsor Casino and CAW, 2007 CanLII 62083 (ON PEHT).
Hugh MacDonald et al v Ontario (Community Safety and Correctional Services),
2014 CanLII 76836 (ON PSGB),
Hasted/Berezowsky v. Ontario (Community Safety and Correctional Services),
CanLII 7473 (ON PSGB) Jan 18, 2016 (Nairn)
Association of Management, Administrative and Professional Crown Employees of
Ontario (Association) v Ontario (Treasury Board Secretariat), 2015 CanLII 90154
(ON GSB) (Misra);
Rotondo v Ontario (Community and Social Services), 2017 CanLII 39681 (ON
PSGB)
Stevenson Memorial Hospital v. Ontario Public Service Employees Union, Local
360, 2000 CanLII 22419 (ON PEHT)
Laird v. Ontario (Ministry of Community Safety and Correctional Services), 2005
CanLII 53192 (ON PSGB) (O’Neil),
Mroz v. Ontario (Ministry of Community Safety and Correctional Services), 2012
CanLII 17222 (ON PSGB) (O’Neil).