HomeMy WebLinkAbout2010-2210.Union.18-10-10 DecisionCrown Employees Grievance Settlement
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GSB# 2010-2210
UNION# G-61-08
IN THE MATTER OF AN ARBITRATION
Under
THE CROWN EMPLOYEES COLLECTIVE BARGAINING ACT
Before
THE GRIEVANCE SETTLEMENT BOARD
BETWEEN
Amalgamated Transit Union – Local 1587
(Union) Union
- and -
The Crown in Right of Ontario
(Metrolinx) Employer
BEFORE
Nimal Dissanayake
Arbitrator
FOR THE UNION
Ian Fellows
Ursel Phillips Fellows Hopkinson LLP
Counsel
Kassia Bonisteel
Ursel Phillips Fellows Hopkinson LLP
Counsel
FOR THE EMPLOYER Glenn Christie
Hicks Morley Hamilton Stewart Storie LLP
Counsel
HEARING September 25, 2018
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DECISION
[1] This decision relates to a request by the union that the Board order that the
employer recall two of its witnesses who had completed their testimony. To put
this issue into context, it is useful to review the background to this proceeding,
which is about a policy grievance filed back on June 16, 2008. It is convenient
to reproduce that background as set out in the Board`s decision dated October
14, 2015 at paragraph 1-10 as follows:
[1] This is a proceeding with a history. A policy grievance dated June
16, 2008, was heard by the Board over eight days, and its
decision was issued on August 12, 2014. An application for
judicial review by the employer was heard by the Divisional Court
on June 25, 2015. Its decision was released on July 27, 2015.
[2] The grievance raised the issue of whether or not seven positions
were included within the bargaining unit represented by the union.
The union took the position that it had bargaining rights with respect
to an “all employee” unit under the recognition clause of the
collective agreement. It submitted in the alternative that if the Board
finds the language in the recognition clause to be ambiguous,
evidence relating to negotiating history and past practice would
support its position. It further argued that the employer was
estopped for asserting that the bargaining unit was not an “all
employee” unit. The employer disagreed.
[3] The second dispute relating to the scope of the bargaining unit was
about whether or not office and technical employees were excluded
from the bargaining unit. The employer asserted that they were
excluded. The union took the position that the language excluding
“office and technical staff” was inserted in the collective agreement
by mistake, and urged to Board to exercise its power to rectify. In
the alternative, the union asserted that the employer was estopped
from claiming an exclusion of office and technical employees.
[4] For purposes of this decision, it is sufficient to note that the Board
held that the union was not entitled to an all employee bargaining
unit. The union’s arguments based on negotiating history and past
practice, as well as its estoppel argument were rejected. The Board
concluded that the “all employee” language in the recognition clause
was qualified by the words “as specified in Schedule A1 and A2, or
as developed through the application of Article 9”.
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[5] On the second issue in dispute, the Board upheld the union’s
position. It held that the language in the recognition clause excluding
“office and technical staff” was included as a result of a mistake on
the part of the employer who prepared the language to be signed off,
and that such an exclusion was not consistent with the agreement
reached during bargaining. The Board applied the equitable
doctrine of rectification to delete that exclusionary language from the
recognition clause.
[6] In its application for judicial review of the Board’s decision, the
employer focussed on the Board’s decision to rectify the language
in the recognition clause. The Court’s conclusion is summed up at
para 2 of its judgement, where Swinton J. wrote:
[2] In my view, the Vice-Chair of the Board reasonably
concluded that rectification was an appropriate remedy on the
facts of the case. He reasonably directed that the erroneous
language, placed in the agreement as a result of error, should
be removed. However, the interpretation that he gave to the
rectified article and the ultimate order to the parties to agree
on new language in the collective agreement were not
reasonable. Accordingly, I would allow the application for
judicial review and set aside that part of the award interpreting
the rectified article and ordering the parties to agree on new
language.
[7] By way of remedy, the Court directed as fellows at para 41:
[41] With respect to the remedy of rectification, the only
aspect of the decision that is unreasonable is the order to the
parties to agree on new language. That aspect of the award
is severable from the rest of the award. Accordingly, I would
allow the application for judicial review, set aside that part of
the award ordering the parties to agree on new language that
reflects an all employee O/T unit. This would leave in place
the Board’s order that the language of the collective
agreements in issue be amended to delete the exclusion of
O/T staff from Article 2.1.
[8] With that background, I turn to the issue presently before the Board.
Following the court decision, the issue of the inclusion/exclusion of
the seven positions identified by the parties to be in dispute was still
to be determined. When the Board convened, the union sought to
argue that in light of the recognition clause as rectified, all office and
technical positions were in the bargaining unit, whether or not they
meet the requirement in the recognition clause, “as specified in
Schedule A1 and Schedule A2, or as developed through the
application of Article 9,” and that the employer is in any event
estopped from asserting a contrary position.
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[9] The employer took the position that the union is not entitled to
advance that argument. Counsel contended that the issue had been
already decided by the Board in its decision, and the Board’s
interpretation in that regard had been upheld by the court. It took
the position that the issue of the interpretation of the scope of the
bargaining unit had been determined and the only remaining issue
was whether seven specific positions were in or out of the bargaining
unit in light of the rectified language. The Board was functus and
had no jurisdiction to hear more evidence and submissions on the
issue of the scope of the bargaining unit. Counsel also submitted
that the issue the union seeks to argue is precluded by the doctrine
of res judicata, and would amount to an abuse of process. (For ease
of reference all of the arguments by the employer are hereinafter
referred to as “the functus motion”).
[10] Once the foregoing dispute was joined, the employer moved that the
Board hear and determine its motion as a preliminary matter, before
dealing with the merits of the grievance relating to the
inclusion/exclusion of the seven specific positions. The union urged
the Board to deal with the functus motion as well as the merits, and
rule on all issues at the conclusion of the hearing. This decision
deals solely with the issue of whether or not those two matters
should be heard together as proposed by the union, or bifurcated as
proposed by the employer.
[2] In its decisions dated October 14, 2015, and November 01, 2016 the Board
determined, for reasons set out therein, that the motion would not be heard as
a preliminary matter.
[3] Therefore, the hearing resumed on January 24, 2017 on the merits of the union’s
claim that certain positions treated by the employer as excluded from the
bargaining unit, should be included in the bargaining unit. Hearings continued on
January 25, 26; October 12, 13, 18, 31; November 6; and December 8 of 2017,
during which time the union called five witnesses.
[4] When the Board convened next on September 25, 2018, union counsel advised
that the union was closing its case. The parties requested that the Board address
a dispute that had arisen between the parties before starting the employer’s
evidence. Union counsel advised that two of the employer’s witnesses, Mr. Brent
Morrison and Mr. Graham Walker, who had testified in this proceeding (which
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resulted in the original decision dated August 12, 2014, and the judgement of the
Ontario Divisional Court dated July 27, 2015) had subsequently testified before
this Board, differently constituted, with Chair Susan Stewart. The union asserted
that those witnesses had given testimony before Chair Stewart which was
significantly different than their testimony before me, in relation to matters relevant
to the interpretation of the scope of the recognition clause in the collective
agreement. Counsel particularly asserted that it came to the union’s attention for
the first time during the testimony of the witnesses before Chair Stewart, that in
determining whether or not a newly created position was in or outside the
bargaining unit, the employer was guided by, and used, two internal documents.
It was alleged that in testimony before me, the witnesses had not stated that those
documents had been used. Nor had the documents been disclosed to the union.
[5] Counsel pointed out that on consent the two documents had subsequently been
entered as exhibits in the instant proceeding as exhibits 32 and 33. Counsel
requested that the Board order that the employer recall the two witnesses in
question, so that he would have an opportunity to cross-examine them about the
two documents in question and the manner in which they were used.
[6] During their submissions, from time to time both counsel kept referring to the issue
of whether the union was entitled to make further arguments on the interpretation
of the recognition clause as rectified, or whether the Board has already interpreted
that clause. However as earlier decided by the Board in its decisions dated
October 14, 2015 and November 1, 2016, that issue would be argued and decided
by the Board at the conclusion of the hearings on the grievance. The issue
presently is whether, if the determination is that the union is entitled to further
argue the interpretation issue, the union should be given the opportunity to rely
on the evidence it seeks to adduce by recalling the two employer witnesses in
question. The Board is asked to determine whether the union’s request for an
order for recalling those two witnesses, which is opposed by the employer, should
be allowed.
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[7] As directed by the Board, the union filed particulars. Employer counsel agreed
that for purposes of the motion seeking an order to recall witnesses only, the
Board may make its determination based on those particulars. Those particulars
are as follows;
Particulars Respecting Exhibits 32 and 33
The following particulars are provided on a without prejudice basis.
Brent Morrison
1. On January 17, 2014, Brent Morrison was called as a witness for Metrolinx to give
evidence before Arbitrator Dissanayake in the “Fail to Post” matter.
2. During Mr. Morrison’s direct examination by counsel for Metrolinx, he was asked
questions respecting what he used/relied on to determine whether a position was
included/excluded from the bargaining unit. In response, Mr. Morrison testified that
he would look to Schedules A1 and A2 and Article 9 for guidance as to whether a
position was included/excluded from the bargaining unit.
3. Counsel for Metrolinx asked Mr. Morrison whether there was anything in addition
to Schedules A1 and A2 and Article 9 that he used for guidance. Mr. Morrison
testified before Arbitrator Dissanayake that he did not use anything else to
determine whether a position was included or excluded from the bargaining unit.
4. During Mr. Morrison’s direct examination before Arbitrator Dissanayake he also
testified that if a job was not similar to a bargaining unit position he would deem it
a non-bargaining unit position. He would also look at whether the department had
bargaining unit positions.
5. Mark Gallina was present during Mr. Morrison’s testimony before Arbitrator
Dissanayake as he was Metrolinx’s advisor on that day.
6. On October 4, 2017, Mr. Morrison was called as a witness for Metrolinx to give
evidence in the “UPX/Presto” matter before Chair Stewart.
7. During Mr. Morrison’s direct examination before Chair Stewart he identified that
there was in fact a document that he referred to in determining whether a position
was included or excluded from the bargaining unit. This document is Exhibit 33.
8. Mr. Morrison testified before Chair Stewart that he referred to Exhibit 33
“frequently”.
9. Mr. Morrison testified before Chair Stewart that Exhibit 33 set out the “nature of the
work” that would prevent a position from being included in the bargaining unit. Mr.
Morrison stated that Exhibit 33 contained the “criteria about whether [a] job [was]
included or excluded” and “[t]hat would have been [the] criteria that kept it out of
the Union”.
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Graham Walker
10. On April 25, 2014, Graham Walker was called as a witness for Metrolinx to give
evidence before Arbitrator Dissanayake in the “Fail to Post” matter.
11. Mr. Walker did not give any evidence before Arbitrator Dissanayake related to
Exhibit 33.
12. Mr. Walker testified before Arbitrator Dissanayake that he did not have a role in
the development of new positions.
13. Mr. Walker testified before Arbitrator Dissanayake that he would speak to Mr.
Morrison and ask him how he came to determine whether a new position was
included or excluded from the bargaining unit. Mr. Walker testified that Mr.
Morrison would state that he tried to find a comparable job in the bargaining unit,
and if he couldn’t, he would deem it a non-bargaining unit position.
14. Mark Gallina was present during Mr. Walker’s testimony before Arbitrator
Dissanayake as he was Metrolinx’s advisor on that day.
15. On January 31, 2018, Mr. Walker was called as a witness for Metrolinx to give
evidence in the “UPX/Presto” matter before Chair Stewart.
16. Mr. Walker testified before Chair Stewart that he gave Exhibit 33 to Mr. Morrison.
17. Mr. Walker testified before Chair Stewart that Exhibit 33 was a guide to help
determine whether a position was in the bargaining unit. Mr. Walker testified that
Exhibit 33 was “just to get the managers to really focus on whether it is unionized
or non-bargaining unit”.
Mark Gallina
18. Mark Gallina was Metrolinx’s advisor and present on January 17 and April 25,
2014, during the evidence of Mr. Morrison and Mr. Walker in the “Fail to Post”
matter before Arbitrator Dissanayake.
19. Mr. Gallina did not give evidence in the “Fail to Post” matter before Arbitrator
Dissanayake.
20. On February 7, 2018, Mr. Gallina was called as a witness for Metrolinx to give
evidence in the “UPX/Presto” matter before Chair Stewart.
21. Mr. Gallina testified before Chair Stewart that he drafted Exhibit 32 in 2010 or 2011.
22. Exhibit 33 is copied into Exhibit 32. Therefore, Mr. Gallina has been aware of the
existence of Exhibit 33 since in or around 2010, and was aware of Exhibit 33 when
Mr. Morrison and Mr. Walker gave evidence in the “Fail to Post” matter before
Arbitrator Dissanayake.
23. However, Mr. Gallina did not produce Exhibits 32 or 33 to the Union in the “Fail to
Post” matter nor did he advise Arbitrator Dissanayake that Exhibits 32 or 33
existed.
24. Mr. Gallina testified before Chair Stewart that he drafted Exhibit 32 “for the purpose
of helping out total rewards person [compensation analysist] make the distinction
of whether a person should be in or out of the bargaining unit”.
25. Mr. Gallina testified before Chair Stewart that Exhibit 32 was “to capture the
processes or criteria that had been used to, at that time, to identify whether a
position would be in or not” as well as “helps [Metrolinx] identify the type of
positions that have been included historically and therefore would likely be similar
to new positions.
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26. Mr. Gallina also testified that his advice as to whether new position would be
included in the bargaining unit included whether it “makes labour relations sense
to include the position” in the bargaining unit. Mr. Gallina confirmed that it would
make labour relations sense to include a new position in the bargaining unit where
the new position works side by side with bargaining unit members or reports to the
same supervisor.
[8] It was agreed that the following should be added to the union’s particulars: “Exhibit
33, being the document titled, “Confidential Labour Relations and Confidential
Interest Examination”, was received by Graham Walker from Go Transit/Metrolinx
legal counsel sometime between 2002 and 2005”.
[9] Although reference was made to two documents, exhibits 32 and 33, the focus
was on exhibit 33 which the parties agreed had existed since at least 2005. It
reads as follows:
CONFIDENTIAL LABOUR RELATIONS AND
CONFLICT OF INTEREST EXAMINATION
Determine whether the following duties/responsibilities fall within the employee’s
position:
1. Does the employee perform duties that involved confidential
information pertaining to employee relations? For example:
- grievances/employee complaints
- hiring/firing
- bargaining and preparation for bargaining (i.e. Preparation of supporting
data)
- attendance at management meetings where bargaining issues and
strategies are discussed
- transcribing and/or otherwise handling minutes of management minutes
- dealing with correspondence that contains information related to labour
relations
- interpreting/administering collective agreements
- preparing reports and manipulating data relating to staff/position changes,
salary projections, staff retirements, costing
- budget projections
- resolving employee concerns on any LTD/WSIB/pension issues
- knowledge regarding lay-offs, cutbacks, contracts with outside parties
2. Does the employee perform duties that involve confidential information
in other aspects of the business? For example:
. legal settlements
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. operational decisions
. confidential information regarding management employees
. confidential information regarding bargaining unit employees
For all of the information collected above, determine the following:
- How much of the employee’s time is spent on these duties?
- Are these duties a regular part of the employee’s position?
- Does the employee have access to the information only or does the
employee actually use the information to perform his/her job?
- Is the information to which the employee has access made available to
the union?
- Will the information used by the employee be provided to the public, such
that it loses its confidential nature?
[10] The evidence is that well after the filing of the instant grievance, sometime in 2010-
11 exhibit 32 was created by the employer by adding the following to the content
of exhibit 33:
As per the Crown Employees Collective Bargaining Act, employees who
exercise managerial functions or are employed in a confidential capacity
in relation to labour relations” are excluded from any bargaining unit. In
addition, the exclusions at s.1.1(3) of CECBA also include the following
general exclusion:
Other persons who have duties or responsibilities that, in the opinion of
the Ontario Labour Relations Board, constitute a conflict of interest with
their being members of a bargaining unit.
Perhaps in accordance with this general exclusion, a practise has
emerged whereby, with the introduction of a new position, a decision as
to that position’s inclusion or exclusion is made in the Compensation
Office. Although not formalized, the following criteria have been used:
. Included if position is mostly clerical in nature
. Coordinators are usually included
. Administrators are usually included
. Administrative assistant are excluded
. Excluded if employee contributes or is exposed to long range planning
. Excluded if involves research
. Excluded if work involves legal settlements
. Excluded if work involves operational decisions
. Excluded if work involves exposure to staff or position changes, salary
projections, staff retirements, budget projections, layoffs, cutbacks,
contracts with third parties, resolution of employee concerns regarding
LTD, WSIB or pension issues.
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. Excluded if belonging to any of the specifically excluded groups at
section 1.1(3) of CECBA.
Since exhibit 32 post-dates the filing of the grievance, hereafter I would only be
referring to exhibit 33.
[11] Counsel for the union submitted that if Mr. Morrison used exhibit 33 in deciding
whether the positions in issue in this proceeding were in or out of the bargaining
unit as he testified before Chair Stewart, it is arguably relevant and should have
been produced by the employer. Unfortunately, it did not do so, and the union
became aware of it only in 2017 during the Chair Stewart hearing. Therefore, the
union was deprived of an opportunity to cross-examine Mr. Morrison about his use
of the document. Counsel argued that evidence relating to Mr. Morrison’s use of
exhibit 33 is also relevant to the Board’s interpretation of what jobs are included in
the bargaining unit under article 9 of the collective agreement. Counsel submitted
that in the circumstances the evidence before the Board at present is inaccurate.
Mr. Morrison’s testimony that he did not refer to anything other than schedules A-
1 and A-2 in deciding whether to include or exclude newly created positions is
grossly in error. For the Board to decide the grievance on the basis of such
erroneous evidence would be unfair and would result in a grave miscarriage of
justice.
[12] Employer counsel agreed that pursuant to s. 48(12) of the Labour Relations Act
the Board has jurisdiction to order that witnesses who had completed their
testimony be recalled in appropriate circumstances. The issue is whether the
Board should exercise that jurisdiction in the particular circumstances of this case.
He submitted that the Board should not exercise that jurisdiction. Counsel
submitted that the only error the union points to relates to the evidence of Mr.
Morrison in this proceeding that he did not use anything other than the two
schedules when deciding whether new positions are in or out of the bargaining
unit. It is alleged that in the Chair Stewart proceeding Mr. Morrison had testified
that he used exhibit 33 frequently.
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[13] Counsel pointed out that the union does not allege that what Mr. Morrison stated
before Chair Stewart negates any of his testimony in this proceeding. There is no
claim that Mr. Morrison testified in the Chair Stewart proceeding that he used only
exhibit 33. Thus, the alleged error is only to the effect that he failed to mention in
this proceeding that he also used exhibit 33. While Mr. Morrison may have stated
in the Chair Stewart proceeding that he frequently referred to that exhibit, there is
no evidence that he testified as to the purpose for that frequent reference.
[14] Employer counsel submitted that there is absolutely no basis for ordering that Mr.
Walker be recalled, since there cannot be, and there is no suggestion, that he
gave contradictory evidence in the two proceedings. The union claims that Mr.
Walker testified before Chair Stewart that he gave exhibit 33 to Mr. Morrison and
described exhibit 33 as a guide to help determine whether a position was in the
bargaining unit. The union particulars also confirm that in this proceeding Mr.
Walker did not give any evidence related to exhibit 33.
[15] Counsel submitted that if Mr. Morrison did in fact use exhibit 33 it is irrelevant in
this proceeding, which relates to seven specific newly created positions. Exhibit
33 is only about exclusion of positions from the bargaining unit pursuant to the
Crown Employees Collective Bargaining Act on the basis of “confidential” duties.
The union is not relying on CECBA in claiming that any of the seven positions are
included in the bargaining unit. Rather, its argument is that the new positions
perform duties very similar to those performed by existing bargaining unit
positions, and are in reality the same positions although with different position
titles. Therefore, whether or not Mr. Morrison used exhibit 33, or how he used it,
would have no relevance to that issue.
[16] In reply, union counsel asserted that evidence to the effect that Mr. Morrison in
fact used exhibit 33 does serve a useful purpose, in that it would support the
position the union has always taken, that Mr. Morrison made his decisions based
solely on the CECBA criteria for exclusion. Before Chair Stewart, Mr. Morrison
had testified that the nature of the duties that would exclude a position from the
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bargaining unit is described in exhibit 33. In this proceeding Mr. Walker also
spoke only about comparable jobs in the bargaining unit. However, in the Chair
Stewart arbitration he testified that exhibit 33 was a guide in determining whether
a position is in or out of the bargaining unit.
[17] DECISION
The parties are in agreement that the Board has the jurisdiction to order the recall
of a witness. The issue, therefore, is whether the Board should exercise its
discretion in the particular circumstances.
[18] The union counsel’s argument that denial of its request that Mr. Morrison and Mr.
Walker be recalled would result in unfairness and a miscarriage of justice is based
on his assertion that in this proceeding Mr. Morrison testified that in making his
decisions he only looked at whether there was a bargaining unit position which
was comparable, and when asked whether he looked at anything else other than
the two schedules he stated that he did not. The particulars, accepted by the
employer for purposes of this motion, show that contrary to that testimony, Mr.
Morrison did use exhibit 33. Thus counsel submits that in this proceeding Mr.
Morrison’s evidence was that he made his decision solely based on existence of
comparable union positions. Therefore, if Mr. Morrison is not ordered recalled,
the Board would be deciding the grievance based on untrue evidence. Similarly,
Mr. Walker appeared to support Mr. Morrison’s inaccurate testimony, by not
referring to exhibit 33 in this proceeding and limiting his testimony to comparable
bargaining unit positions.
[19] I have reviewed my notes on Mr. Morrison`s testimony before me tendered on
January 17, 2014. His testimony was very brief and he was not cross-examined.
In chief, the following exchange took place as per my notes:
Q: Did you ever have to decide whether a job is in or out of the bargaining unit?
A: Yes.
Q: How was that decided?
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A: I`ll look for similar jobs if the position is unionized. If there was no similar
unionized jobs I`ll make it non-bargaining unit.
Q: Recall examples of departments that had unionized jobs?
A: IT, Communications, Finance.
Q: Any departments that were not unionized?
A: Yes. Legal, Human Resources, anyone reporting to executive. I believe rail
services and strategic planning were also not unionized.
Q: What other things did you look at when deciding?
A: If the job supervises or makes recommendations on workforce planning those
are deemed to be non-union. Also jobs that are highly confidential – if a position
is involved in planning bus routes and driver services for example.
Q: Did you look at anything in the collective agreement for guidance?
A: Only schedules A-1 and A-2 which list union jobs.
Q: Anything else in the collective agreement?
A: No.
Q: What is article 9?
A: That is about how we evaluate union jobs to assign a pay rate.
Q: Did anything in article 9 help you decide if a job is in or out?
A: No.
Q: Did you use anything else to make your decision?
A: I believe thats it.
Q: Is it your decision whether a position is in or out of the union?
A: Its in partnership with the department. As I was experienced they trusted me.
[20] Although Mr. Morrison testified that he did not look at “anything else”, and did not
mention referring to Exhibit 33, his testimony was not to the effect that he only
looked at comparable bargaining unit positions as union counsel asserts.
Although not mentioning any particular document or the CECBA, he did testify
that positions that had “supervision” and positions that were “confidential” were
excluded. Whether he considered those criteria by referring to exhibit 33, some
other document or case law, or his familiarity with the CECBA provisions, that in
my opinion would not be of significance. Mr. Morrison has testified before the
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Board that in addition to considering the existence of comparable union positions,
he considered the criteria of managerial and confidential exclusions.
[21] In the circumstances, it was open to the union, if it was of the view that Mr.
Morrison made his decision solely based on the CECBA criteria, to have cross-
examined him. Moreover, as employer counsel pointed out, the seven positions
in dispute are not being claimed by the union based on the CECBA. Its position
is that those positions are very similar to existing bargaining unit positions, and
that they should be included in the bargaining unit on that basis. The union is
certainly entitled to establish that the comparison with union positions undertaken
by Mr. Morrison and his conclusion based on the comparison was incorrect. As
noted, Mr. Morrison had testified that he did the comparison in making his
decisions. If the union so wished, it was open to it to challenge Mr. Morrison on
that evidence. The absence of exhibit 33 or testimony from Mr. Morrison that he
used it did not deprive the union of the opportunity of doing so. If Mr. Morrison
and/or Mr. Walker are ordered recalled their examination would not provide the
union a second opportunity for an open-ended cross-examination. Any
examination would necessarily be strictly limited to exhibit 33 and Mr. Morrison’s
use of it. These related only to managerial and confidential CECBA exclusions.
Since the union’s claim is not based on CECBA that evidence will not serve any
useful purpose. Recalling of witnesses is an extra-ordinary departure from the
norm, and is not to be resorted to in these circumstances.
[22] For the foregoing reasons the Board is of the view no unfairness or miscarriage
of justice would result unless the requested order is granted. The request is,
therefore, denied.
Dated at Toronto, Ontario this 10th day of October, 2018.
“Nimal Dissanayake”
______________________
Nimal Dissanayake, Arbitrator