HomeMy WebLinkAbout2005-3289.Union.07-07-23 Decision
Crown Employees
Grievance Settlement
Board
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Commission de
reglement des griefs
des employes de la
Couronne
Bureau 600
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Toronto (Ontario) M5G 1Z8
Tel. : (416) 326-1388
Telec. : (416) 326-1396
IN THE MATTER OF AN ARBITRATION
Under
Nj
~
Ontario
GSB# 2005-3289
UNION# 2005-0999-0030
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
BETWEEN
BEFORE
FOR THE UNION
FOR THE EMPLOYER
HEARING
Before
THE GRIEVANCE SETTLEMENT BOARD
Ontario Public Service Employees Union
(Union Grievance)
- and -
The Crown in Right of Ontario
(Ministry of Health and Long-Term Care)
Owen V. Gray
David Wright
Ryder Wright Blair & Holmes LLP
Barristers and Solicitors
Fateh Salim
Counsel
Ministry of Government Services
April 12, June 11, July 10,2007.
Union
Employer
Vice-Chair
2
Decision
[1] In this proceeding the union challenges the employer's termination in November
2005 of what the union describes as a "policy" of paying extra compensation to land
ambulance dispatchers when they provide mentoring to new dispatchers. The union
claims that the employer is obliged to continue paying the extra compensation for the
life of the current collective agreement. That obligation is said to arise from an estoppel
based on the employer's conduct, and not from any express or implied provision of the
collective agreement.
[2] After their opening statements the parties identified certain facts on which they
could agree and outlined the testimony that their witnesses would give. They each then
agreed that the other's witnesses would testify as described, and that this dispute could
be argued and determined as though such testimony had been given, on the basis of
that testimony and the agreed facts.
The Facts
[3] This decision refers to the affected employees as "dispatchers" for ease of
reference, but their formal job titles are "Communications Officer" and
"Communications Supervisor." During the term of the previous collective agreement,
those two land ambulance dispatcher positions were classified as "Communications
Officer 2" and "Communications Officer 3," respectively. The Communication Officer
class standards applied to communications officers in a variety of positions in the
Ontario public service, not just to those who dispatched land ambulances for the
Ministry of Health and Long-Term Care. Concurrent with the advent of the current
collective agreement, the affected employees' positions were reclassified as "Ambulance
Communications Officer I" and "Ambulance Communications Officer 2," respectively.
As their name implies, the new Ambulance Communications Officer class standards
apply only to ambulance dispatchers.
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[4] The "policy" that the union says the employer is obliged to continue applying was
announced by the employer in a memorandum issued in September 2002 (hereafter, the
"mentoring compensation memorandum"):
Emergency Health Services Branch
Effective Date: September 23, 2002
Communications Officer Mentoring Program - Compensation Pilot Proiect
For
Ministrv Operated Central Ambulance Communications Centres
This pilot project is being introduced to address concerns about workload
management and competing priorities for C02 and C03 employees who, in addition
to their routine duties, act as mentors for newly hired communications officers who
are entering the mentoring phase of their job learning.
Upon hiring, a communications officer candidate typically undergoes a multi-part,
standardized training program prior to commencing mentoring. Upon successful
completion of the required core and local training programs delivered by
Communications Training Officers (CTO) and approved training resources, the
communications officer candidate is ready for local mentoring placement at their
home CACC. Local mentoring typically lasts a minimum of six (6) weeks. During the
mentoring phase, the candidate's training is consolidated in a real-world setting
under the guidance of an experienced communicator.
Although dispatching duties must take priority over mentoring activities, it is
recognized that communicators incur an additional workload when mentoring new
staff. Typically, this work takes the form of preparation and evaluation activities
related to the day-to-day practical aspects of call taking and dispatching. Evaluation
involves observing and noting new communications officer's performance throughout
the shift and completing an end of shift performance summary report.
Under this pilot project the manager will compensate communicators, who are
suitable and agree to provide mentoring activities, for preparation time for the
mentoring shift. A participating communicator who undertakes an authorized eight
(8) hour mentoring shift shall be entitled to one and one half (1.5) additional hours of
pay at the overtime rate. Longer shifts involve more mentoring evaluation,
documentation and summation work. Consequently, a participating communicator
who undertakes an authorized twelve (12) hour mentoring shift shall be entitled to
an additional two (2) hours of pay at the overtime rate.
For greater certainty:
8 hour shift = 8 hours at straight time (8 x 1 = 8 hours)
plus 1.5 hours at overtime (1.5 x 1.5 = 2.25 hours)total is 10.25 hours
of pay at the employee's basic hourly rate
12 hour shift = 12 hours at straight time (12 x 1 = 12 hours)
plus 2 hours at overtime (2 x 1.5 = 3 hours)
total is 15 hours of pay at the employee's basic hourly rate
It is anticipated that this pilot project will help ensure that the preparation and
evaluation of mentoring activities related to the practical aspects of call taking and
dispatching are completed appropriately.
This pilot project will be evaluated after a suitable time frame.
[5] The memorandum says that in addition to performing his/her regular
dispatching duties during a shift in which s/he mentors a new dispatcher, a dispatcher
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who mentors is also expected to spend a certain amount of time on preparation for
mentoring and on "evaluation, documentation and summation work" concerning the
new dispatcher. It seems to dictate or pre-estimate the amount of time these additional
duties should take, preauthorize that amount of overtime work and undertake that
compensation for that time will be paid to the mentor at overtime rates in addition to
his/her regular pay for the regular shift hours. A casual reader of the memorandum
might infer that dispatchers who mentor were expected and required to spend more
time at work than those who just perform their regular dispatching duties. On that
view, an undertaking to pay for the pre-authorized additional time at overtime rates
would be unremarkable and entirely consistent with the employer's obligations under
the collective agreement then in force.
[6] What I have said that a casual reader might have concluded was not what was
intended or understood or implemented, however. Dispatchers who mentored were not
actually expected or required to spend more time performing their combined mentoring
and regular dispatching duties than non-mentoring dispatchers were expected to spend
on their regular dispatching duties alone. What might appear to be an undertaking to
pay mentors for pre-authorized additional work time at overtime rates was actually
understood by all concerned to be an undertaking to provide extra compensation not
authorized or required by the collective agreement (but calculated by reference to what
it would require the employer to pay for some notional overtime hours) for each regular
shift during which mentoring was performed.
[7] The employer issued the mentoring compensation memorandum and began
paying the mentoring bonus after a series of health and safety work refusals, primarily
in Oshawa, in which dispatchers refused to participate in mentoring new dispatchers.
In that connection the Union had taken the position that mentoring duties were not
part of the dispatchers' jobs and had also alleged that their performing them increased
the dispatchers' job stress to the detriment of their health.
[8] The employer's witnesses would testify that when it implemented the mentoring
compensation pilot project it thought that perhaps the then applicable class standards
and job descriptions did not sufficiently flesh out a requirement that dispatchers
participate in providing training. The Ministry was going through a major recruitment
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drive and needed lots of experienced dispatchers to assist in training new ones. It also
recognized that dispatchers were underpaid, and that this project provided a means of
improving their compensation pending a more comprehensive solution to that problem.
There is no suggestion that the employer shared any of these thoughts with the union
at any material time, however, nor that the employer ever expressly agreed with the
union that mentoring duties were not part of the dispatchers' jobs as they were then
defined. The union's claim that mentoring was not part of the dispatchers' jobs was
never adjudicated.
[9] The employer implemented the mentoring bonus unilaterally. It did not seek or
obtain the union's agreement to it. The union was aware of the mentoring compensation
memorandum and that, as a result, dispatchers who mentored were being paid more
that those who did not for the same number of hours worked. It did not challenge the
employer's practice of paying the mentoring bonus.
[10] The parties later settled some grievances and OLRB proceedings relating to
benefits and alleged strike reprisals in a Memorandum of Settlement dated May 17,
2004. The terms of that agreement included an increase in the maximum pay for
dispatchers (by adding two higher paid steps to the salary grid for their positions) and a
pay increase for all land ambulance dispatchers (by moving all existing dispatchers up
two steps on the grid). The agreement also provided as follows:
3. Class Standards
The Employer will carry out and conclude a review of the existing
Communications Operator class standards by October 31, 2004. This review will
include Air Ambulance positions in Emergency Health Services. Any monetary
outcomes will be negotiated in the next round of bargaining.
During the negotiations that led to this settlement agreement no one said anything
about whether or not the project described in the mentoring compensation
memorandum and the resulting practice of paying the mentoring bonus would continue
after the results of a review of the class standards were implemented. Nothing at all
was said in that connection about the memorandum, the pilot project, the mentoring
bonus or extra pay for mentoring.
[11] Later in 2004, the employer circulated proposed new class standards for a new,
separate Ambulance Communications Officer class series, as well as new position
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descriptions for the land ambulance dispatcher positions of Communications Officer
and Communications Supervisor, which were to be classified as Ambulance
Communications Officer 1 and Ambulance Communications Officer 2, respectively.
Before finalizing the new class standards, the employer consulted with the appropriate
union officials and with employees of the different communications centres. During
those consultations no one said anything about whether or not the project described in
the mentoring compensation memorandum or the resulting practice of paying the
mentoring bonus would continue after the new class standards and job descriptions
were implemented. Nothing at all was said in that connection about the 2002
memorandum, the pilot project, the mentoring bonus or extra pay for mentoring.
[12] The collective agreement in effect when the mentoring bonus was implemented
expired at the end of 2004. During negotiations for the renewal of that agreement, the
parties negotiated pay rates for land ambulance dispatcher positions with reference to
the new class standards and job descriptions for them. The pay rates on which they
agreed provided dispatchers with a substantial increase: employer witnesses would
have testified (without contradiction) that the pay increase was 34 percent over the
dispatchers' 2002 pay levels.
[13] During that collective bargaining no one said anything about whether or not the
project described in the mentoring compensation memorandum and the resulting
practice of paying the mentoring bonus would continue for the redefined and
reclassified dispatcher positions when the negotiated changes came into effect. Nothing
at all was said in bargaining about the memorandum, the pilot project or the mentoring
bonus. Neither party proposed that there be different pay rates, or additional pay, for
dispatchers when they mentor new dispatchers. Nothing in the resulting collective
agreement requires that dispatchers be paid more when they mentor new dispatchers.
[14] After the terms of the new collective agreement were settled in 2005, around the
time it expected that the negotiated pay increases would be implemented, the employer
issued the following on memorandum (hereafter, the "wrap-up memorandum") dated
October 20, 2005:
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MEMORANDUM TO: Ambulance Communications Officers Ministry of Health
and Long-Term Care Central Ambulance Communications
Centres
FROM: Tony Campeau
Manager, Land Ambulance Programs
RE: Wrap-up of Mentoring-Compensation Pilot Project
As many of you are aware, the ministry operated CACCs have faced some significant
challenges over the past few years. One of the most important of those challenges
was the recruitment, training and retention of Communications Officers. I am
pleased to notify you that through the dedication and effort of ministry operated
CACC staff and management we have been successful in meeting this challenge.
In order to collectively meet our recruitment, training and retention challenges, a
number of changes needed to occur. These changes included the development of new
position descriptions to better reflect the duties and responsibilities of CACC staff, an
improved collective agreement and an improved CORE training program. One of the
temporary measures that helped us manage the challenges was the Mentoring-
Compensation Pilot Project. This temporary project was put into place to recognize
staff who were tasked with the responsibility of on-the-job training of new
Communications Officers while the other above noted improvements were being
pursued.
The new position description and the new class standards for Ambulance
Communications Officers recognize the responsibility of providing on -the-job training
for new staff as part of the core job duties. As a result of this recognition and the
compensation for this role in the new OPSEU collective agreement, the Mentoring
Compensation Pilot Project is wrapping up effective November 6, 2005.
Employees who incur overtime while training new staff will be compensated for that
overtime as per the collective agreement, if it is authorized by the manager.
For those of you who participated in the Project over the past 3 years, I would like to
extend our appreciation for your commitment and professionalism in assisting new
staff prepare for their career as Ambulance Communications Officers. Although the
Project is now complete, the role of all experienced Ambulance Communicators in
shaping the future of new staff through the on-the-job training remains vital to the
success of the new communicators in their chosen careers. It is also vital to the
success and quality of emergency health services communications across the
prOVInce.
Thank you for your continuing professionalism in the dispatching of ambulance
servIces.
[15] The employer says, and the union accepts, that the considerations identified in
the second paragraph of the wrap-up memorandum were considerations when the
employer's adopted the policy or pilot project described in the 2002 mentoring
compensation memorandum and implemented the resulting practice of paying a
mentoring bonus. The employer's witnesses would testify that the obligation of
dispatchers to participate in providing training was elaborated in the new class
standards and job descriptions, as the wrap-up memorandum stated, that the
dispatchers' compensation was addressed in bargaining and (as I have already noted)
8
that the dispatchers received a 34 per cent increase in pay relative to 2002 pay levels.
The employer also says, and the union accepts, that the reasons it gave in the wrap-up
memorandum for wrapping up the project were its actual reasons for doing so.
[16] The union's witnesses would testify that the matter of additional pay for
mentoring was not raised as an issue in bargaining for the current collective
agreement, either with the union by affected employees or by the union in negotiations
with the employer, because (as far is it was concerned) there had been no indication
that the project described in the mentoring compensation memorandum and the
resulting practice of paying the mentoring bonus would end on the implementation of
the new class standards. They would say that the union saw no significance to the new
class standards on this issue, since the old class standards and job specifications had
also spoken to training. Had the union understood that the employer saw it differently,
they would say, the union would have proposed additional pay for mentoring during
negotiations for the current collective agreement.
Argument
[17] The union argued that an estoppel arises from the employer's having failed to
give the union notice during collective bargaining that it intended to discontinue its
practice of paying a mentoring bonus, because had the union known of the employer's
intention to do so it would have sought to negotiate that practice into the collective
agreement, and its having foregone the opportunity to do that will have been to its
detriment if the employer is permitted to rely on its strict legal rights with respect to
payment for mentoring under the new collective agreement.
[18] The union submitted that part of the context supporting such an estoppel was
the employer's agreement in 2004 that it would negotiate any "monetary outcomes" of
its review of the applicable class standards during subsequent collective bargaining. In
the wrap-up memorandum the employer identified the new class standards and job
descriptions as reasons for discontinuing the mentoring bonus. That showed that in the
employer's mind the discontinuance was an outcome of its review of the applicable class
standards. Since that outcome was monetary in nature it was something that the 2004
agreement had obliged the employer to raise explicitly during collective bargaining. In
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this connection the UnIon submitted that because the class standards and job
descriptions in force in 2002 also spoke to training, the references to training in the new
class standards and job descriptions did not represent a significant change in that
regard and gave it no warning or notice of the prospect that additional pay for
mentoring might be discontinued. Thus, in the union's submission the employer's
silence at the bargaining table about the prospect of its discontinuing the mentoring
bonus amounted to a representation that it would not be discontinued during the term
of the collective agreement for which they were bargaining.
[19] In support of its submissions, the union's counsel cited Re Maple Lodge Farms
Ltd. and United Food & Commercial Workers, Local 175(1991), 24 L.A.C. (4th) 211 (R.
M. Brown), Re Stirling Place and United Food and Commercial Workers International
Union, Local 175/633 (1997), 62 L.A.C. 289 (Pineau) and Re Hamilton-Wentworth
Catholic District School Board and Ontario English Catholic Teachers Association
(2005), 144 L.A.C. (4th) 70 (Herman). He submitted that the Maple Lodge Farms award
identified a "general rule" that when a compensation practice not reflected in the
collective agreement exists at the time of bargaining for renewal of the agreement and
the employer does not give the union express notice during bargaining that it will not
consider the practice binding for the life of the renewal agreement, the employer will be
estopped from changing that practice for the life of that renewal agreement. He argued
that the language used in the 2002 mentoring compensation memorandum, particularly
the use of the phrase "pilot project" to describe the project and the statement in the last
sentence that the pilot project would be "evaluated after a suitable time frame," did not
amount to notice that the employer would not consider the resulting practice binding
for the life of the renewal agreement.
[20] The union argued in the alternative that even if the employer's silence at the
bargaining table about extra compensation for mentoring was not a representation that
its practice of paying such compensation would continue for the life of the agreement, in
view of paragraph 3 the 2004 settlement agreement it was at least a representation
that the outcome of its review of the class standards would have no impact on the
continuation of that practice. The union submitted that even on this view of the
representation, the employer was estopped from discontinuing the practice on the basis
of changes in class standards.
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[21] The employer argued that there was no unequivocal representation of the sort
that could support the estoppel contended for by the union here. The practice of paying
extra compensation for mentoring was introduced unilaterally as "pilot project" that
was to be evaluated after a "suitable time frame." A "pilot project" is a project of limited
duration that mayor may not continue in a greater or lesser form after review but
cannot be expected to continue indefinitely. The memorandum was not a representation
that the practice would continue for the life of the next collective agreement, and was
not intended to affect the employer's legal relationship with the union.
[22] The employer noted that the pilot project was adopted in part because the union
had taken the position that mentoring was not part of the job of ambulance
communications officers under the then applicable job descriptions and class standards.
New class standards and job descriptions were devised making it clear that mentoring
would be part of the job. The monetary outcomes of those new class standards for
Ambulance Communications Officers were negotiated in 2005 as the parties' agreement
in 2004 had contemplated. Substantially higher wage rates were the result. If the union
had wanted dispatchers to be paid different pay rates depending on whether or not they
were mentoring, or if it wanted a commitment that the pilot project would extended to
the new jobs for the life of the contract, then in the employer's submission the union
had had the obligation to raise that at the bargaining table.
[23] Employer counsel cited the requirements of estoppel as described by this Board
(differently constituted) in Brown, 0513/86 (Barrett) at pages 6-8 as quoted in Hawke
870/90 (Fisher) at pages 3 and 4. He also referred to Re Chronicle Journal and CEP,
Loc. 191 (2003), 117 L.A.C. (4th) 385, which rejected the distinction that arbitrator
Surdykowski felt the Maple Lodge Farms and Stirling Place awards had made between
compensation and other collective agreement issues when it comes to the application of
estoppel in circumstances where there is nothing in a collective agreement about a
particular issue. Reference was also made to Re Atomic Energy of Canada Ltd. and
Atomic Energy Labour Alliance (1986), 22 L.A.C. (3d) 225 (Swan), Re Janes Family
Foods and United Food and Commercial Workers International Union, Local1000A
(2006) 156 L.A.C. (4th) 304 (Trachuk) and Canadian National Rallway Co. and CA. W
Canada, Loc. 100(2005), 137 L.A.C. 282 (Jones).
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[24] With respect to the alternate argument described in paragraph [20] above,
employer counsel initially expressed concern that it went beyond the scope of this
grievance by seeking, in effect, a remedy for an alleged breach of the 2004 agreement.
When union counsel confirmed that that agreement was only relied on as part of the
context in which silence at the bargaining table was said to amount to a basis for the
estoppel claimed by the union, employer counsel noted that changes to the class
standards were not the only reason given for wrapping up the pilot project and that
even if the employer's silence amounted to a representation about the impact of changes
in class standards on pay for mentoring it should not have the remedial consequence
sought by the union. He asked for an opportunity to research that remedial issue and
make additional argument about it at a later date. His concern in that regard was
resolved by the parties' agreement that both parties would have a further opportunity
to make submissions on the appropriate remedial consequences if I were to find the
basis for an estoppel of some sort in the conduct relied on by the union.
Analysis and Decision
[25] Chief Justice Dickson described estoppel this way in Scotsburn Cooperative
Services Ltd. v. W T Goodwin Ltd. (1985), 16 D.L.R. (4th) 161 (S.C.C.) at pp. 168-9:
The essence of estoppel is representation by words or conduct which induces
detrimental reliance. A more exhaustive definition is offered in Spencer Bower and
Turner, The Law Relating to Estoppel by Representation, 3rd ed. (1977), at p. 4:
[W]here one person ("the representor") has made a representation to another
person ("the representee") in words or by acts or conduct, or (being under a duty
to the representee to speak or act) by silence or inaction, with the intention
(actual or presumptive), and with the result, of inducing the representee on the
faith of such representation to alter his position to his detriment, the representor,
in any litigation which may after-words take place between him and the
representee, is estopped as against the representee, from making or attempting
to establish by evidence, any averment substantially at variance with his former
representation, if the representee at the proper time, and in the proper manner
objects thereto.
This Board (differently constituted) described estoppel in Brown, 0513/86 (Barrett), at
pages 6 - 8 (as quoted in as quoted in Hawke, 870/90 (Fisher), at pages 3 and 4):
1. The party with the contractual right makes a representation to the other party
that it will not be insisting on strict compliance with that right. The representation
need not be expressed but can be implied from the conduct of the party making it.
The conduct gives rise to an estoppel only where it leads the promise reasonably to
believe that an undertaking was being given.
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2. The representation relied upon must be clear and unequivocal. Conduct which is
ambiguous or subject to a number of conflicting interpretations cannot form the basis
of an estoppel.
3. The promise must be one that is voluntarily given; not extracted by force or
coerCIOn.
4. The promise must be one which was intended, or was reasonably construed as
being intended, to affect the legal relations between the parties. A person may well
grant an indulgence without ever intending to forego his strict legal rights. The
promisor is not estopped from relying on terms which in the past have not been
enforced through error or inadvertence.
5. The person relying on estoppel must show that he altered his position on the
strength of the promise or representation that was made. An alteration of position
may take the form of a positive act or that of an omission. It is sufficient the promisee
has been induced to conduct himself differently than he otherwise would have done.
Such conduct must be shown however to have been in reliance on the promise. In the
labour relations context reliance may take the form of forebearing to raise an issue at
the bargaining table which but for the promise would otherwise have been raised.
6. It must be shown that the alteration of position by the promisee was to his
detriment or prejudice.
In essence the object of the doctrine is to prevent a party from acting in a manner
inconsistent with an expense [sic] or implied promise, when to do so would be
unconscionable.
[26] In Re CN/CP Telecommunications and Canadian Telecommunications Union
(1981), 4 L.A.C. (3d) 205, arbitrator Beatty applied the doctrine of estoppel to require
that an employer continue a long standing practice of paying weekly indemnity benefits
from the first day of sickness for certain categories of employees, even though the
applicable collective agreement provided that there would be a waiting period before
such benefits would be payable. In his judgment dismissing an application for judicial
review of that award (reported as Re Canadian National Railway Co. et al. and Beatty
et al. (1981), 128 D.L.R. (3d) 236 (Ont. Div. Ct.)), Mr. Justice Osler noted (at p. 241 of
the report) that
The arbitrator found as a fact, as he was bound to do in view of the agreed statement,
that the employer adhered to a course of conduct which reasonably induced the union
to believe that the entitlement of the employees in question to sickness benefits
would not be governed by the strict legal rights set out in art. 30 but rather would
conform to the long-standing practice of paying wages during a waiting period. He
found also that it would be inequitable to allow the employer to insist on the terms of
art. 30 as the limit of its obligation to the employees. As submitted to the arbitrator
by the union, if there had been any indication given by the employer that it had
intended to commence applying the terms of art. 30 strictly despite the opposite
practice of so many years, the union would have had the opportunity of seeking to
negotiate a clause in the agreement to preclude the employer from so doing. At the
foot ofp. 10 of his award (Record, p. 14) the arbitrator finds:
The detrimental reliance then of assuming the practice would continue, lies
in the union's inability to require the employer to negotiate its change in its
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practice during the life this agreement. Mter a practice of this duration, if the
employer anticipated changing it, it had an "affirmative duty" to alert the union
of its intention in order to give it an opportunity to negotiate a note of the kind
the parties fashioned for their vacation package.
Justice Osler further observed (at pp. 243-4) that
What the arbitrator did here, however, was not to interpret the agreement but to
make a finding as to its proper application and to give consequential relief.
That finding surely fits within the principles enunciated by Denning L.J. in
Combe v. Combe, cited above. By its conduct in persistently paying many
classifications of employees from the first day of illness in the face of a clause
providing for a waiting period, the company gave the union an assurance which was
intended to affect the legal relations between them. The union took the company at
its word and refrained from requesting a formal change in the agreement. The
company should not now be allowed to revert to the previous relations as if no such
assurance had been given.
[27] Prior to the award in CN/CP and subsequent court judgment, some arbitrators
had said that the doctrine of estoppel could be used as a "shield" against the assertion
of rights but not as a "sword" to create rights, and there were debates about how the
one sort of use was to be distinguished from the other. In Re Hallmark Containers Ltd.
and Canadian Paperworkers Union, Local 303 (1983), 8 L.A.C. (3d) 117, arbitrator
Burkett commented that the CN/CP award and the judgment on judicial review had put
an end to the sword/shield distinction, but added this caution:
... The elimination of the distinction does not mean, as has been suggested by some,
that a union can enforce all longstanding work place practices by way of estoppel if
the employer has not reserved his right to alter these practices during the term of the
agreement. Indeed, given the statutory requirement that a collective agreement be in
writing and the broad discretion usually given to management under the
management's rights clause of a collective agreement, this would be a strange result.
There may be work place practices which do not conform to the express terms of the
collective agreement, as a payment of weekly indemnity benefits during the three-
day waiting period did not conform to the weekly indemnity provisions in CN/CP,
supra. The failure of an employer to reserve his right at the bargaining table to alter
this type of practice may, as in CN/CP, supra, give rise to an estoppel. However,
there are innumerable other work place practices which exist at the discretion of
management under the management rights clause and are not referable to any other
provision of the collective agreement. It is generally accepted in labour/management
relations that in the absence of specific language in the agreement to codify these
practices, they exist at the discretion of the employer. It could hardly be found,
therefore, that silence at the bargaining table with respect to these types of practices
constitutes a representation by the employer that he is waiving his right to change
them during the term of the agreement. That is not to say, however, that a
representation by the employer at the bargaining table that he will maintain an
existing practice, might not serve to estop the employer from subsequently relying on
his authority under the management rights clause to modify the practice during the
term of the agreement.
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[28] I have reviewed the awards cited by the parties as well as many of the awards
cited in those awards. The facts dealt with in those awards dealt were materially
different from the facts of this case. Accordingly, with one exception I do not intend to
refer to them directly in this decision.
[29] At the heart of any estoppel claim are questions of fact: what representation was
made and what detrimental reliance, if any, did it induce? When representation by
conduct is alleged, the representation alleged must be shown to have been the
unequivocal implication of the conduct in the context in which it occurred. To show that
one party's act or failure to act was induced by the words or conduct of the other, it is
not enough to establish that the action or inaction was that party's subjective reaction
to the words or conduct. If the response was not the reaction actually intended by the
party making the representation, it must at least be shown to be the foreseeable and
objectively reasonable reaction to the representation before the representation can be
said to have induced the response.
[30] Many reported awards have arisen out of an employer's discontinuing a practice
more favourable to its employees than the applicable collective agreement required. In
such cases the union generally asserts that if it had known during negotiations for that
collective agreement that the employer would thereafter discontinue the practice, it
would have bargained to add the practice to the employer's obligations under the
collective agreement. That is not enough to support a finding that estoppel prevents the
employer from altering the practice for the life of the agreement, however. Before it can
achieve that, the union must establish that before or during that bargaining the
employer represented by its words or conduct that it would continue the practice for the
life of the ensuing collective agreement, and that it was that representation that
induced it not to raise the matter in bargaining.
[31] In Maple Lodge Farms, supra, arbitrator Brown found as a fact that the
employer had represented to the union that it would continue the practice in question
for the life of the collective agreement:
On the evidence before me, I conclude that the employer's conduct induced union
representatives to believe this practice would not be terminated during the life of the
collective agreement and that this belief was reasonable.
15
(page 220 of the report). I do not understand the lengthy reasons that precede this
finding to say that if a practice concerns compensation the mere existence of the
practice will compel such a finding despite any surrounding circumstances that would
otherwise support a contrary conclusion. I do not understand the Sterling Place award
to stand for that proposition either. If either of those awards does stand for that
proposition, however, then I respectfully decline to follow it.
[32] The origins of the practice in issue here are not lost in the mists of time at a
distance spanned by multiple collective agreements. It began in late 2002, during the
term of the most recently expired collective agreement. It was implemented
unilaterally. Whether or not the union was right in its claim that mentoring was not
one of the duties contemplated by the class standards and job descriptions then
applicable to dispatchers, payment of the mentoring bonus implemented by the
employer was clearly not provided for in the collective agreement. There was no reason
for the union to believe that the practice reflected an employer belief - reasonable or
otherwise - that the collective agreement required the payment.
[33] When the practice of paying a mentoring bonus was introduced, the employer
expressly described it as a "pilot project" that would be evaluated at a future time. As
the Concise Oxford Dictionary notes (9th ed., Clarendon Press, 1995, at p. 1036), a
"pilot" project is an "experimental undertaking or test." A test project comes to an end
when the tester decides to end it and continue, enlarge or discontinue the activities of
the project. The language that the employer used when it implemented the practice was
a clear reservation, if any was needed, of its right to discontinue the practice at a time
of the employer's choosing. The fact that that time was not specified in advance did not
diminish the reservation.
[34] Leaving aside for a moment any effect the 2004 agreement may have had on the
significance of the employer's silence about the practice in bargaining, the initial
reservation of a right to evaluate the practice at any time, and by implication
discontinue it at any time, had not been withdrawn, altered or diminished by any words
or conduct of the employer when the parties began bargaining for the renewal of their
collective agreement. In that context I would conclude that the past payment of a
mentoring bonus to dispatchers, in combination with the parties' silence about it at the
16
bargaining table, did not amount to a representation or undertaking by the employer
that such payments would continue for the newly reclassified dispatcher jobs for the life
of the next collective agreement.
[35] How does the parties' 2004 agreement affect the meanIng of the employer's
silence about mentoring bonuses during bargaining in 2005?
[36] On this issue counsel debated whether the admittedly different words used
reflect significant differences between the old Communication Officer class standards
and the new Ambulance Communication Officer class standards as regards the duty of
dispatchers to participate in training and mentoring of new dispatchers. On this point
it is significant that the union has not said of the new class standards and job
descriptions, as it did of the old ones, that mentoring is not part of the jobs thus
defined. In any event, in considering the effect of the 2004 agreement on the meaning of
silence in bargaining I do not think it matters whether there was an objectively
significant difference between the old and new class standards as regards training and
mentoring duties.
[37] Paragraph 3 of the 2004 agreement said that the employer would review the
class standards that applied to dispatcher positions, and that "Any monetary outcomes
will be negotiated in the next round of bargaining." The parties presumably intended
this to be something more than mere acknowledgement of an opportunity they would
have had in any event. Whatever it added to the parties' obligations, however, nothing
in the language used suggested that the addition was anything but mutual.
[38] The focus of the provision was on having the compensation for any reclassified
positions dealt with at the bargaining table. It is counterintuitive that an agreement
with that focus could add weight to a claim that something that was not negotiated at
the bargaining table should thereafter determine compensation for a reclassified
position. Having specifically agreed beforehand that compensation for newly
reclassified positions would be dealt with at the bargaining table, it was not reasonable
for the union to have believed that some issue of compensation specific to the newly
reclassified dispatcher positions would be determined by a pre-reclassification,
unilateral employer practice that had not even been discussed, rather than by a
provision that had been both discussed and agreed upon at the bargaining table.
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[39] From the employer's perspective, its proposals at the bargaining table did cover
compensation for mentoring for the newly reclassified dispatcher positions: the wages
rates offered were rates to be paid to employees performing the duties contemplated by
the new class standards and job descriptions, duties which included mentoring.
Assessed against a background that included the parties' express agreement that
compensation for these positions would be negotiated at the bargaining table, the
union's failure to propose a mentoring bonus at the bargaining table was a
representation that no such bonus would be sought or expected for the newly
reclassified positions.
[40] In short, the 2004 settlement agreement does nothing to enhance the union's
claim to an estoppel.
[41] Considered in the context of what the employer said in the 2002 mentoring
compensation memorandum and what the parties agreed to in paragraph 3 of the 2004
memorandum of settlement, the employer's silence at the bargaining table about the
mentoring compensation pilot project and the payment of bonuses for mentoring was
not a representation to the union that the reclassification of the dispatcher positions
would not result in the termination of the mentoring compensation pilot project.
Accordingly, I need not consider whether such a representation could have been the
basis of an estoppel in the circumstances of this case, where reclassification was not the
only reason given for the discontinuance.
[42] Further to my observations in paragraph [34] above, when paragraph 3 of the
2004 memorandum of settlement is added to the analysis my conclusion remains the
same: the employer's silence at the bargaining table about the mentoring compensation
pilot project and payment of extra compensation for mentoring was not a
representation that dispatchers would be paid a mentoring bonus during the life of the
collective agreement for which the parties were bargaining.
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[43] For those reasons the union's estoppel claim fails, and this grIevance IS
dismissed.
Dated at Toronto this 23rd day of July, 2007.